Sanctions Compliance: A Unique Approach for Conglomerates
The U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) January 2022 settlement agreement with Sojitz (Hong Kong)…
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…
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…
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…
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:…
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…