Erich Ferrari August 23, 2018 They’re Ba-ack….JCPOA Withdrawal Nearing Completion with E.O. 13846 There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from…
Erich Ferrari March 21, 2018 Is the OFAC SDN List the New Playground for Identity Thieves? Last month, the United States Court of Appeals for the D.C. Circuit issued an opinion in Chichakli v. Tillerson. For…
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 November 8, 2017 Ummm What? Dastranj v. Dehghan On August 17, 2017, the United States District Court for the District of Maryland issued a memorandum opinion granting in…
Erich Ferrari August 28, 2017 New Venezuela Sanctions–Sectoral Sanctions Without the Sectors? Perhaps lost amidst the weekend’s news of Hurricane Harvey, Seb Gorka resigning, and Joe Arpaio being pardoned, was the announcement…
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 January 16, 2017 IEEPA: So Easy Even a Caveman Can Understand It Here goes my sour grapes post. There have been a number of motions to dismiss filed by defendants in criminal…
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:…