Erich Ferrari December 28, 2010 Discover and Wells Fargo Banks Settle OFAC Violations Last week the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) issued a civil penalties report.…
Erich Ferrari September 15, 2010 Hay Fever: When Authorized Exports to Iran Go Wrong Over the past year or so I have written a couple of postings on the Haystack software. This software was…
Erich Ferrari August 21, 2010 No More Rugs, Pistachios, or Caviar; All Iranian Origin Imports Banned After waiting anxiously for the past six (6) weeks, OFAC has finally issued guidance on how the import ban found…
Erich Ferrari June 28, 2010 Just Say No: Prohibitions on Havaleh between the U.S. and Iran I was recently asked by the Public Affairs Alliance of Iranian Americans (“PAAIA”) to write a short article on the…
Erich Ferrari June 17, 2010 There Goes The Neighborhood…Not Really Yesterday, the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) amended the Iranian Transactions Regulations (“ITR”);…
Erich Ferrari April 15, 2010 Haystack Is a Go When the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) issued a general license permitting the…
Erich Ferrari April 11, 2010 OFAC Struggling to Track Changing Names? According to a recent article from the Wall Street Journal, Iran’s state shipping company has changed the names and ownership…
Erich Ferrari March 17, 2010 To Non-U.S Bank or to U.S. Bank; That is the Question There are a number of things confusing about the sanctions regulations administered by the United States Department of the Treasury…
Erich Ferrari March 11, 2010 Upon Further Review…General License for Personal Communications Software On Tuesday, I wrote about the general license issued by the United States Department of the Treasury Office of Foreign…
Erich Ferrari March 10, 2010 OFAC General License for Internet Based Personal Communications Services Yesterday, the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) issued the long awaited Personal Communications…