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…
Erich Ferrari December 22, 2015 Because OFAC Says So There is a perception common amongst those practicing in the field of U.S. economic sanctions, that the United States Department…
Erich Ferrari December 7, 2015 For Whom OFAC Tolls As almost all people reading this blog know, the United States Department of the Treasury's Office of Foreign Assets Control…
Erich Ferrari November 29, 2015 Fallout From New OFAC SDN Designation May Uncover Details on Syria-ISIS Oil Trade Theory Last week, the United States Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated four individuals and six…
Erich Ferrari November 13, 2015 See You At The Crossroads: OFAC Says Goodbye to an Old Friend Executive Order 13348 had a good run. But when the United Nations rescinded Security Council Resolution 1521 earlier this year,…
Margaret Ververis November 5, 2015 Compliance for Trade Brokers under the ITSR: When is an OFAC License Required? The Iranian Transactions and Sanctions Regulations ("ITSR") administered by the United States Department of the Treasury's Office of Foreign Assets…
Margaret Ververis October 30, 2015 Gil Travel Enforcement Action Teaches Lesson About Compliance On October 27, 2015, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a web…
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 23, 2015 Unless You’re the Former Attorney General, Don’t Try This at Home: An Unusual OFAC License is Granted I came across an interesting opinion from the United States District Court for the District of Columbia the other day…
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…