OFAC General License H: The H is for Hold Your Horses
Unless you've been living under a rock since last Friday, you have probably heard that Implementation Day--the day in which…
Fallout From New OFAC SDN Designation May Uncover Details on Syria-ISIS Oil Trade Theory
Last week, the United States Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated four individuals and six…
Unless You’re the Former Attorney General, Don’t Try This at Home: An Unusual OFAC License is Granted
I came across an interesting opinion from the United States District Court for the District of Columbia the other day…
Head Scratcher of the Week: S.Res.251
Last Thursday, Rep. Johnson (R-Wis) introduced a Senate resolution concerning the validity of the Joint Comprehensive Plan of Action ("JCPOA").…
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…
Houston We Have a Problem: Iran Sanctions Criminal Indictment Misses The Mark
Before we get started, this post is in no way intended to slam Houston, TX or the United States Attorney’s…
Parsing the New Cuba FAQs
Yesterday, OFAC issued an update to the Frequently Asked Questions (“FAQs”) on the Cuban Assets Control Regulations (“CACR”) and in…
CASE STUDY: Sale of Shares in an SDN Entity
Recently, we had an opportunity to successfully represent a private individual who held assets in an Iranian entity obtain a…
One Reason Why Foreign Financial Institutions Might Be Blocking CBI’s Funds
For nearly two (2) years, we have received numerous questions regarding amounts frozen in the bank accounts of foreign financial…
How Should Foreign Financial Institutions Treat Executive Order 13608 Designees
Sometimes forgotten in the long and growing list of Executive Orders directing sanctions to be imposed against various alleged bad…