Tyler Cullis June 15, 2017 Congress Seeks Review Process for Sanctions Easing. Precedent for the Future? The Senate has taken a big step towards reclaiming Congress' prerogatives over the application of U.S. economic sanctions, including, in…
Tyler Cullis June 12, 2017 OFAC Settles Apparent Violations of the CACR On June 8, 2017, OFAC announced a settlement with the American Honda Finance Corporation for apparent violations of the CACR.…
Tyler Cullis June 5, 2017 Epsilon Gives Insight into Scope of Iran Export Ban The DC Circuit Court of Appeals engaged in an interpretive exercise as to the scope of the Iran export ban…
Tyler Cullis May 26, 2017 OFAC Takes Aggressive Action Against Venezuela On May 18, 2017, acting pursuant to Executive Order 13692, OFAC designated eight members of Venezuela’s Supreme Court of Justice…
Tyler Cullis May 22, 2017 Inaugurating the Terrorist Financing Targeting Center The United States has entered a historic agreement with its Gulf Arab partners to target terror finance networks. But is…
Tyler Cullis May 19, 2017 Have We Entered a New Phase of Iran Sanctions? Some allege that the Trump administration is taking a more punitive approach towards Tehran.
Tyler Cullis April 26, 2017 OFAC Issues FAQs on Delisting Petitions On April 20, 2017, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Frequently Asked…
Erich Ferrari April 12, 2017 ZTE Case Highlights Problem with OFAC Enforcement Guidelines I like the General Factors Affecting Administrative Action. I really do. If you don’t know what I’m talking about, allow…
Tyler Cullis March 28, 2017 Does New Senate Bill Designate IRGC a Terrorist Group? The answer is more complicated than might be expected.
Tyler Cullis March 6, 2017 Is There a “Policy Gap” in IRGC Sanctions? Is there a "policy gap" regarding U.S. sanctions targeting the IRGC and its designated agents or affiliates? Proposed legislation seems…