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 September 26, 2013 The Hangover: OFAC Targets Mexican Tequila Maker Earlier this week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on a…
Erich Ferrari September 9, 2013 More NDAA 1245 Waivers Issued By U.S. Government On Friday, the United States announced that it had extended sanctions waivers to ten (10) European Nations and Japan due…
Erich Ferrari August 29, 2013 The OFAC FOIA Fiasco: The Story Of Joaquin Mario Valencia-Trujillo Let me start off this post by saying that the Freedom of Information Act (FOIA) office at the U.S. Department…
Erich Ferrari May 3, 2013 SDNY Strikes Again: A Kingpin Has Arrived In America Last week the United States Attorney’s Office for the Southern District of New York (USAO SDNY) announced the extradition of…
Erich Ferrari March 25, 2013 Does OFAC’s Policy on Licensing Release of Blocked Funds for SDN Reconsiderations Unfairly Limit U.S. Persons? As I was reading back through the licensing policy statement of the United States Department of the Treasury’s Office of…
Erich Ferrari March 7, 2013 The Iran-TRA’s Secondary Sanctions Trap I have been getting a lot of questions lately about the Iran Threat Reduction and Syrian Human Rights Act of…
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 March 3, 2013 Criminal Investments: The New Trend in IEEPA Criminal Cases There is a terrifying trend in the world of criminal prosecutions for sanctions related offenses these days. More and more…