A Little Bit of Guidance on OFAC General License G
Recently, I reviewed a response by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) to…
Clean Up Duty: OFAC Acknowledges an Unblocking Under the 50 Percent Rule and Re-issues Venezuela-related General Licenses
Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it was issuing two…
OFAC Continues Iran Designations Despite COVID-19 Outbreak
Despite most of the world being in self-quarantine mode to prevent the spread if COVID-19, the United States Department of…
Common Problem, Uncommon Consequence: The State Street Bank and Trust OFAC Enforcement Matter
Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of a…
The Evolution of OFAC General Licenses for Legal Services
The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has discretion to both specifically license particular…
Three Tips for Filing an OFAC License Application to Unblock Funds
Every day, funds transfers are blocked by U.S. financial institutions and others due a belief that the blocking is necessary…
Shock Gen: The Dangers of the OFAC Voluntary Self-Disclosure
Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Société…
They’re Ba-ack….JCPOA Withdrawal Nearing Completion with E.O. 13846
There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from…
IP Services Under The ITSR: A Broad Exception?
If you’ve ever heard me speak at a conference or seminar on U.S. sanctions, then you’ll know one of my…