Erich Ferrari June 3, 2019 Common Problem, Uncommon Consequence: The State Street Bank and Trust OFAC Enforcement Matter Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of a…
Erich Ferrari December 22, 2017 You Talking to Me? The ITSR, Iranians, and Ordinary Residency Just because you are a citizen of Iran does not mean that the Iranian Transactions and Sanctions Regulations (“ITSR”) prohibit…
Erich Ferrari December 18, 2017 Crypto-Craze: Will Sanctions Evaders Turn to Cryptocurrencies to Beat OFAC? If you don’t watch the news, go on the internet, or have friends, then you probably haven’t heard of cryptocurrencies,…
Erich Ferrari December 11, 2017 Factoring In OFAC’s Enforcement Guidelines From what I understand the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), sends out over…
Erich Ferrari April 12, 2017 ZTE Case Highlights Problem with OFAC Enforcement Guidelines I like the General Factors Affecting Administrative Action. I really do. If you don’t know what I’m talking about, allow…
Erich Ferrari November 1, 2016 Fright Night: OFAC, the Iranian Transactions and Sanctions Regulations, and the Dangers of Websites Halloween was yesterday, but there was still something scary on my desk when I walked into the office this morning:…
Erich Ferrari September 17, 2016 Flower Power: Does OFAC’s Recent Enforcement Announcement Highlight Common Misunderstanding? This week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had settled…
Erich Ferrari June 22, 2016 Three Tips for Responding to OFAC Administrative Subpoenas It’s been a long time since I’ve written a “how to” piece on SanctionLaw–or anywhere else for that matter. However,…
Erich Ferrari March 9, 2016 And Still Undefeated Heavyweight Champion of the World….. OFAC K.O.’s Epsilon Lawsuit My apologies for the title, I just finished watching Creed. Yesterday, the Honorable Reggie B. Walton of the United States…