Erich Ferrari January 19, 2016 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…
Tyler Cullis January 14, 2016 OFAC’s Iran Sanctions Guidance Is Imminent Sometime between now and next week, OFAC will release detailed guidance relating to sanctions-relief on Iran. Whether it succeeds or…
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…
Tyler Cullis January 5, 2016 Congress Begins to Target President’s Licensing Powers Recently, some in Congress have expressed hostilities towards the President’s broad licensing powers under the International Emergency Economic Powers Act…
Erich Ferrari October 27, 2015 Websites for Marketing of Dietary Supplements to Iran Exempt Under the Information or Informational Materials Exemption As readers of this blog may know, dietary supplements are generally authorized for export to Iran, pursuant to the general…
Erich Ferrari September 17, 2015 The House Gets Desperate on Iran Sanctions Deal It is rare for me to write anything about the sanctions debate going on in Congress. However, it is unprecedented…
Samuel Cutler February 10, 2015 Judge Leon Will Not Be Deterred: Fokker Case Will Not Be Deferred In a stunning move, United States District Court Judge Richard Leon, who Erich has dubbed “The Lion of Constitution Avenue”…
Erich Ferrari November 11, 2013 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…
Erich Ferrari November 7, 2013 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…
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…