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 October 2, 2013 Rise of the Banks While administration of U.S. economic sanctions is legally entrusted to the U.S. Department of the Treasury’s Office of Foreign Assets…
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 September 3, 2013 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…
Erich Ferrari September 3, 2013 Is the De Minimis Rule Still in the ITSR? There have recently been a number of sources reporting that there is no longer a de minimus rule contained in…
Samuel Cutler August 24, 2013 Iranian Tennis Referee Banned From US Open; Not Sanctions’ Fault? On Wednesday the New York Times ran a story entitled “Sanctions Against Iran Mean a Tennis Referee Can’t Work at…
Erich Ferrari August 12, 2013 Burma…Going….Going…But Not Yet Gone Last week, President Obama, in light of the expiration of the Burmese Freedom and Democracy Act’s (BFDA) import ban issued…
Erich Ferrari July 17, 2013 Is OFAC Fed Up With Frivolous License Applications? The heading of this blog posting seems to state a question with an obvious answer: yes, the United States Department…
Erich Ferrari July 6, 2013 OFAC FAQs: The End or Beginning of Your OFAC Inquiry? I hate knocking the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) for the guidance they…
Erich Ferrari June 23, 2013 Could it Be? Are EU Sanctions Culpable in Failure of Food, Medicine Exports to Iran? For over a year now, those in the sanctions policy and legal worlds have been discussing the difficulties that food…