Sanctions Are Hard: OFAC Corrects Their Own FAQ Mistake
If sanctions were easy, we’d be out of a job and there would be no need for this blog. So…
Fokker’s Iran Sanctions Violations Prompt The Roar Of The Lion Of Constitution Avenue
Sometimes I forget how much I like being in Court. On Wednesday, Judge Richard Leon, United States District Court Judge…
OFAC SDNs, Payments, And The Barter System
One of the great ironies you witness over and over again when you practice in the field of U.S. economic…
Planes, Trains, And Automobiles: The Free Trade Zone Exception Myth
Over the course of my career, I have been blessed to have had the opportunity work with companies and individuals…
Aircraft Parts To Iran: Open For Business Or Not Really?
Since last November when the the P5+1 entered into the Joint Plan of Action (“JPOA”) with Iran concerning Iran’s disputed…
Are You Fokkers Crazy?!?!?!
On Thursday, the United States Department the of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced an agreement to…
Iranian Bank Accounts: Criminal Or Civil Or Neither?
We frequently get calls where clients want to know the “approved” banks in Iran they can work with or have…
CASE STUDY: OFAC Licensing For Provision Of Brokerage Services To Third Country Exporter
Last year, I posted an article about a U.S. company that was engaged in prohibited brokerage services on behalf of…
OFAC Upgrades General License D With General D-1
This past Friday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released General License D-1.…
Parsing Sanctions Relief Under The Joint Plan Of Action
By now, most if not all of Sanction Law’s regular readers will have at least glanced at the guidance issued…