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 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 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…
Erich Ferrari October 30, 2013 OFAC Seeks to Break Up Brothers’ Circle Today, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the designation of six (6)…
Erich Ferrari September 20, 2013 OFAC General License D: Is the “D” for Deceiving? Before any officials of the Office of Foreign Assets Control (“OFAC”) or any other U.S. agency takes this post the…
Erich Ferrari September 11, 2013 With Two New General Licenses Is OFAC Attempting to Restore Balance to the Force? Today, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of two (2)…
Samuel Cutler August 24, 2013 Iranian Tennis Referee Banned From US Open; Not Sanctions’ Fault? On Wednesday the New York Times ran a story entitled “Sanctions Against Iran Mean a Tennis Referee Can’t Work at…
Samuel Cutler August 20, 2013 OFAC Goes Silent on Iran In the lead-up to Iran’s elections on June 14, 2013, The United States Department of the Treasury’s Office of Foreign…
Erich Ferrari July 17, 2013 Is OFAC Fed Up With Frivolous License Applications? The heading of this blog posting seems to state a question with an obvious answer: yes, the United States Department…
Erich Ferrari June 27, 2013 Delegation of Authority In Tier I Kingpin OFAC Delisting Cases As I have noted numerous times on this blog not all designations made under the Foreign Narcotics Kingpin Designations Act…