Tyler Cullis February 22, 2017 So You Want to Reside in Iran? If a U.S. person is interested in moving to Iran on a permanent basis, can that U.S. person open a…
Tyler Cullis February 10, 2017 IRGC Sanctions: A (Brief) History Reports indicate that the Trump administration is considering the promulgation of an Executive Order that would direct the Secretary of…
Tyler Cullis February 6, 2017 Is It a New Day in Iran Sanctions? Some are characterizing OFAC's latest designations of Iran-related persons as evidence of a new aggressive posture by the Trump administration.…
Erich Ferrari January 16, 2017 IEEPA: So Easy Even a Caveman Can Understand It Here goes my sour grapes post. There have been a number of motions to dismiss filed by defendants in criminal…
Tyler Cullis January 11, 2017 Did Rex Tillerson Violate the ITSR? Likely Not. Rex Tillerson, PEOTUS's nominee to lead the State Department, is expected to face tough questioning during his nominating hearing this…
Tyler Cullis January 1, 2017 President Amends Cyber Sanctions Executive Order, Sanctions High-Level Russian Government Targets On December 29, 2016, President Obama amended Executive Order 13694 – otherwise known as the ‘Cyber Sanctions Executive Order’ –…
Tyler Cullis December 27, 2016 OFAC Amends ITSR, Permits U.S. Person Training On December 23, 2016, OFAC amended the ITSR – the first substantive amendment to the regulations since the advent of…
Tyler Cullis December 20, 2016 OFAC Issues North Korea-Related General License 1-A OFAC issued General License I-A to the North Korea Sanctions Regulations, rescinding a former license authorization for U.S. financial institutions…
Tyler Cullis December 19, 2016 Does ISA Extension Violate the JCPOA? With enactment of the Iran Sanctions Extension Act, Iran has called for a meeting of the Joint Commission to seek…
Tyler Cullis December 15, 2016 OFAC Amends Iran FAQs, Issues General License J-1 Acting consistent with its pledge to update its Iran-related FAQs as new questions arise from interested parties, OFAC issued revisions…