Samuel Cutler May 15, 2015 OFAC Responds With Motion for Summary Judgment in Epsilon v. Treasury For those of us awaiting new filings in the Epsilon Electronics Inc. v. U.S. Dep’t of Treasury case, the inevitable Motion…
Samuel Cutler May 7, 2015 Why DOJ Thinks Your iPhone Could Support the Iranian Nuclear Program Look around. You are currently surrounded by “dual-use” goods that could contribute to Iran’s nuclear or military programs. If you’ve…
Samuel Cutler April 7, 2015 All That Glitters is not Gold: Dangerous Times for the Iranian-American Community With the announcement by the P5+1 and Iran of a framework agreement aimed at resolving the issue of Iran’s disputed…
Samuel Cutler April 1, 2015 Does the PayPal Settlement Set a Dangerous Precedent? Last week, PayPal agreed to cough up $7,658,300 for violations of a number of different sanctions programs. Between 2009 and…
Samuel Cutler February 22, 2015 Breaking Down The Iran-Russia Oil-For-Goods Deal Samuel Cutler and Matthew Reed explain the practical and legal obstacles that make an oil-for-goods deal between Iran and Russia unlikely. Neither Tehran…
Erich Ferrari January 18, 2015 OFAC Finally Receives A Challenge To An Enforcement Action: The Case Of Epsilon Electronics Every few months we hear the news reports about the United States Department of the Treasury’s Office of Foreign Assets…
Erich Ferrari December 27, 2014 Crimea River: OFAC Imposes Sanctions On The Crimea Lost in all of last week’s news about Cuba sanctions relaxation, and the hustle and bustle preceding the imminent Christmas…
Samuel Cutler December 13, 2014 How Congress Got Their Way And Almost Blew Up The Iran Nuclear Deal Sometime ago my Policy Adviser, Samuel Cutler, wrote an article that was featured on this blog were he highlighted the…
Samuel Cutler November 16, 2014 Mo’ Yanni, Mo’ Problems According to the BBC, Greek pianist Yanni (yes that Yanni) is scheduled to perform shows in Tehran and vacation destination…
Erich Ferrari November 12, 2014 U.S. Persons Assisting Iran’s Tech Startup Community: OFAC Or NOFAC? Over the last several months there has been a lot of buzz around Iran’s technology start-up community and their potential…