Erich Ferrari December 7, 2015 For Whom OFAC Tolls As almost all people reading this blog know, the United States Department of the Treasury's Office of Foreign Assets Control…
Erich Ferrari September 11, 2015 Ready, Set, Wait: How You Can Predict Receiving an OFAC Administrative Subpoena or Grand Jury Subpoena One of the most underreported aspects of the recent cases concerning banks being investigated and penalized by regulators–including the United…
Erich Ferrari September 8, 2015 In Defense of the “Inventory Exception”: Epsilon Electronics Goes All In Readers of SanctionLaw.com may recall an article that I wrote at the beginning of the year concerning the lawsuit brought…
Erich Ferrari September 5, 2015 UBS Settlement Highlights the Need for Local Counsel On August 27, 2015, UBS AG (UBS) and OFAC agreed to settle 222 apparent violations of §594.201 of the Global…
Erich Ferrari May 19, 2015 U.S. to Offer Renewed Car Audio Trade in Exchange for Iranian Concessions on Nuclear Program, Terrorist Financing Yes, the title of this post is a joke. And no, you’re not reading a post from the Onion right…
Erich Ferrari May 17, 2015 Watch Your 602: OFAC Administrative Subpoenas and Non-U.S. Persons If you have any experience dealing with OFAC, the United States Department of the Treasury’s Office of Foreign Assets Control,…
Erich Ferrari May 15, 2015 OFAC Stays Flexible on the ITSR Inventory Exception Several months ago, I was sitting in the hallowed halls of Big Law Firm XYZ talking to a few of…
Erich Ferrari October 28, 2013 Another U.S. Subsidiary of a Foreign Parent Company Leads to OFAC Penalty There is always a lot made of U.S. companies being subjected to liability for sanctions violations for the actions of…
Erich Ferrari August 19, 2013 Visa Gets an OFAC Penalty…or a Notice…or a Warning…or Something Last week the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced an enforcement action against…
Erich Ferrari June 5, 2013 A Sanction for (Almost) Every Reason: President Obama’s New Executive Order I suppose the President has gotten tired of Congress getting all of the attention when it comes to imposing new…