The Power of Paperwork
Economic sanctions regulations administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) change frequently.…
Banks Are Taking the Wrong Position on Travel Transactions Under the ITSR
When is an exemption no longer an exemption? Apparently, when you are a U.S. depository institution attempting to comply with…
OFAC Revises 31 CFR Part 560 as the Iranian Transactions and Sanctions Regulations (ITSR)
Yesterday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a significant revision of 31 CFR…