Erich Ferrari November 8, 2017 Ummm What? Dastranj v. Dehghan On August 17, 2017, the United States District Court for the District of Maryland issued a memorandum opinion granting in…
Erich Ferrari August 28, 2017 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…
Erich Ferrari August 10, 2017 Are you Dreaming of an OFAC SDN Designation? I spend a lot of time online. This is due, in part, to the fact that one of my favorite…
Erich Ferrari July 3, 2017 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…
Erich Ferrari April 12, 2017 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…
Erich Ferrari January 16, 2017 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…
Erich Ferrari December 13, 2016 Is Epsilon Electronics the Donald J. Trump of OFAC Enforcement Cases? I’m going to have to pick up a new hobby once the United States Court of Appeals for the District…
Erich Ferrari November 1, 2016 Fright Night: OFAC, the Iranian Transactions and Sanctions Regulations, and the Dangers of Websites Halloween was yesterday, but there was still something scary on my desk when I walked into the office this morning:…
Erich Ferrari October 20, 2016 Seventh Circuit Makes Quick Work of Defendant’s “Willfulness” Jury Instruction in US v. Turner Anyone that knows me can tell you that I get really disappointed by the way courts have handled the definition…
Erich Ferrari September 20, 2016 Kingpin Act Reporting Requirements: Quarterly or Annual? This post is primarily directed to the members of the criminal defense bar that may be representing defendants who have…