Erich Ferrari September 20, 2013 OFAC General License D: Is the “D” for Deceiving? Before any officials of the Office of Foreign Assets Control (“OFAC”) or any other U.S. agency takes this post the…
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…
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…
Samuel Cutler August 20, 2013 OFAC Goes Silent on Iran In the lead-up to Iran’s elections on June 14, 2013, The United States Department of the Treasury’s Office of Foreign…
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…
Erich Ferrari June 5, 2013 A Sanction for (Almost) Every Reason: President Obama’s New Executive Order I suppose the President has gotten tired of Congress getting all of the attention when it comes to imposing new…
Erich Ferrari May 14, 2013 Iran Sanctions Bonanza: New Designations and Legislation With the Iranian Presidential elections exactly one month away the U.S. has taken the opportunity to ratchet up sanctions on…
Samuel Cutler May 9, 2013 Poor Advisers: Online Travel Agencies Misinterpret OFAC Regulations As sanctions have increased over the years, planning a trip to Tehran has gotten progressively more difficult. A brief review…