Crypto-Craze: Will Sanctions Evaders Turn to Cryptocurrencies to Beat OFAC?
If you don’t watch the news, go on the internet, or have friends, then you probably haven’t heard of cryptocurrencies,…
Factoring In OFAC’s Enforcement Guidelines
From what I understand the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), sends out over…
New Venezuela Sanctions–Sectoral Sanctions Without the Sectors?
Perhaps lost amidst the weekend’s news of Hurricane Harvey, Seb Gorka resigning, and Joe Arpaio being pardoned, was the announcement…
Not Exactly a Line in the Sand: The D.C. Circuit and Attempt Liability Under the ITSR
Admittedly, I’m late to the party on this, but as you likely already know the D.C. Circuit has issued its…
ZTE Case Highlights Problem with OFAC Enforcement Guidelines
I like the General Factors Affecting Administrative Action. I really do. If you don’t know what I’m talking about, allow…
IEEPA: So Easy Even a Caveman Can Understand It
Here goes my sour grapes post. There have been a number of motions to dismiss filed by defendants in criminal…
Better do Your Due Diligence on Doing Due Diligence
Ever since the Joint Plan of Action–the framework to what eventually would become the Joint Comprehensive Plan of Action–was signed…
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…
Paradoxes of the JCPOA Sanctions Relief
It’s only been a few weeks since the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)…
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…