Kian Meshkat April 12, 2022 Sanctions Compliance: A Unique Approach for Conglomerates The U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) January 2022 settlement agreement with Sojitz (Hong Kong)…
Erich Ferrari August 1, 2020 A Little Bit of Guidance on OFAC General License G Recently, I reviewed a response by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) to…
Erich Ferrari March 29, 2020 OFAC Continues Iran Designations Despite COVID-19 Outbreak Despite most of the world being in self-quarantine mode to prevent the spread if COVID-19, the United States Department of…
Erich Ferrari April 18, 2019 The Evolution of OFAC General Licenses for Legal Services The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has discretion to both specifically license particular…
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 July 3, 2017 Not Exactly a Line in the Sand: The D.C. Circuit and Attempt Liability Under the ITSR Admittedly, I’m late to the party on this, but as you likely already know the D.C. Circuit has issued its…
Erich Ferrari December 13, 2016 Is Epsilon Electronics the Donald J. Trump of OFAC Enforcement Cases? I’m going to have to pick up a new hobby once the United States Court of Appeals for the District…
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 June 14, 2016 The Duality of SDN Designations…..You Know the OFAC Thing If you’re on the United States Department of the Treasury’s Office of Foreign Assets Control’s (OFAC) email subscription list, then…
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…