Erich Ferrari May 23, 2013 CASE STUDY: Brokering Agricultural Commodities on Behalf of a Non-U.S. Person A few months ago, we wrote a case study on how the United States Department of the Treasury’s Office of…
Erich Ferrari May 7, 2013 Burma Sanctions Continue to Linger On Last Week President Obama reaffirmed the national emergency in respect to Burma (Myanmar) thereby extending the Burmese sanctions program. Regardless…
Erich Ferrari April 2, 2013 OFAC Updates Electronic Document Submission Guidelines Last week the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidelines for submission of…
Erich Ferrari March 28, 2013 Importance of IMO Numbers Screening Comes to Light in Recent OFAC Enforcement Case Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement in the…
Erich Ferrari March 6, 2013 Another Houston Company Settles With OFAC Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with EGL, Inc.,…
Erich Ferrari January 18, 2013 OFAC Enforcement and Deferred Prosecution Agreements: A New Trend Today the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement between itself and…
Erich Ferrari January 13, 2013 What OFAC’s January 10th Advisory Could Mean This past Thursday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued advisory guidance concerning…
Erich Ferrari January 3, 2013 OFAC Starts Off 2013 With An Enforcement Action On the first business day of the new year, the United States Department of the Treasury’s Office of Foreign Assets…
Erich Ferrari December 23, 2012 2012: Return of the OFAC Penalties Earlier this year, I wrote that it seemed the days of large penalties and settlements for violations of U.S. economic…
Erich Ferrari December 12, 2012 The Upward Spiral: A Timeline of HSBC’s Iran Sanctions Violations Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), announced their second massive penalty of…