Why an OFAC License Is Not the End of OFAC Compliance
In my practice I have found that many people believe a license authorization issued by the United States Department of…
2012: Return of the OFAC Penalties
Earlier this year, I wrote that it seemed the days of large penalties and settlements for violations of U.S. economic…
OFAC Designates M23 Leaders; Are OFAC SDN Reconsiderations All Politics?
Shortly after Thanksgiving I wrote a blog posting calling into question when the United States Department of the Treasury’s Office…
Iranian National and U.S. Citizen Plead Guilty to Iran Sanctions Violations
Yesterday, two individuals, Hamid Asefi and Behzad (Tony) Karimian pleaded guilty to violations of the Iranian Transactions and Sanctions Regulations…
Facilitation, Foreign Subsidiaries, and OFAC Licensing
Maybe it’s because I will be discussing it at this week’s American Conference Institute 2012 OFAC Boot Camp, but the…
When Will We See Sanctions on the M23 and its Leaders?
Reports are pouring in that a Congolese rebel group, M23, has overtaken Goma, a major city in the Democratic Republic…
OFAC Designates the Second Wife of El Chapo
This week the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated the second wife of…
Dissecting Executive Order 13622 Authorizing Additional Sanctions With Respect to Iran
Buried among the flurry of Iran sanctions measures imposed this summer by the United States Government was the little talked…
OFAC Guidance on Iran Earthquake Relief
Over the weekend two large earthquakes occurred in northwestern Iran. Due to the magnitude of these earthquakes, hundreds died, thousands…
OFAC SDN Reconsiderations Through Twitter?
Maybe its a sign of the times, but yesterday I witnessed a group of tweeters (not sure if this is…