Erich Ferrari September 17, 2016 Flower Power: Does OFAC’s Recent Enforcement Announcement Highlight Common Misunderstanding? This week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it had settled…
Erich Ferrari June 22, 2016 Three Tips for Responding to OFAC Administrative Subpoenas It’s been a long time since I’ve written a “how to” piece on SanctionLaw–or anywhere else for that matter. However,…
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…
Erich Ferrari January 13, 2016 Shipping to Afghanistan? How is your OFAC Compliance Program Looking? Over the past year or so, we've seen the United States Department of the Treasury's Office of Foreign Assets Control…
Erich Ferrari September 8, 2015 In Defense of the “Inventory Exception”: Epsilon Electronics Goes All In Readers of SanctionLaw.com may recall an article that I wrote at the beginning of the year concerning the lawsuit brought…
Erich Ferrari May 19, 2015 U.S. to Offer Renewed Car Audio Trade in Exchange for Iranian Concessions on Nuclear Program, Terrorist Financing Yes, the title of this post is a joke. And no, you’re not reading a post from the Onion right…
Erich Ferrari May 17, 2015 Watch Your 602: OFAC Administrative Subpoenas and Non-U.S. Persons If you have any experience dealing with OFAC, the United States Department of the Treasury’s Office of Foreign Assets Control,…
Samuel Cutler June 6, 2013 David Cohen’s Subtle, But Much Needed, Cry for Help During Tuesday’s Senate Banking Committee hearing on Iran sanctions, New Jersey Senator Robert Menendez asked TFI Undersecretary David Cohen a…
Erich Ferrari May 23, 2013 CASE STUDY: Brokering Agricultural Commodities on Behalf of a Non-U.S. Person A few months ago, we wrote a case study on how the United States Department of the Treasury’s Office of…
Erich Ferrari April 2, 2013 OFAC Updates Electronic Document Submission Guidelines Last week the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidelines for submission of…