Government’s Jury Instructions in Online Micro Case Give Insight on the Term “Willful”
Last week the U.S. Attorneys Office prosecuting Masood Habibion, Mohsen Motamedian and Online Micro, LLC for, among other charges, violations…
Download Dangers: U.S. Sanctions and Internet Downloads
There was a recent article written on a Slovakian company which had developed anti-virus software that was being downloaded in…
Reuters Exclusive on Somali Sanctions and OFAC
Yesterday, Reuters came out with an excellent article on the impact of sanctions on Somali pirates. From their article, it…
Weighing in the Cuba Travel Debate
Over the past few weeks there have been a number of articles regarding travel to Cuba and whether certain activities…
How to Make Sense of the Iranian Bank Account Question
A big part of addressing any question related to a transaction impacted by a sanctions program administered by the United…
Is Payment of Ransoms to Somali Pirates Violating OFAC Sanctions?
In a case of damned if you do, damned if you don’t, there are news reports floating around about how…
How Will OFAC Address a Cuban Oil Spill?
Recently questions have been asked regarding whether the restrictions found in the Cuban Assets Control Regulations (“CACR”) will bar U.S.…
New Iran Sanctions Designations
Last week the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) and the Department of State…
Is Your TSRA License Taking Longer Than Usual? Does That Indicate Denial?
Last Friday the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) released its quarterly report on…
Debunking the Myth: Transfers of Less than $10,000 Can Be “Smurfing”
There is a prevailing myth amongst many people that if you transfer money in amounts of less than $10,000 from…