Kingpin Act Reporting Requirements: Quarterly or Annual?
This post is primarily directed to the members of the criminal defense bar that may be representing defendants who have…
Paradoxes of the JCPOA Sanctions Relief
It’s only been a few weeks since the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)…
OFAC General License H: The H is for Hold Your Horses
Unless you've been living under a rock since last Friday, you have probably heard that Implementation Day--the day in which…
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…
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…
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…
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)…
Uncle Sam Says Talk to the Hand (of Justice): No Lobbying for SDNs
This week two individuals from Chicago were arrested for violations of the Zimbabwe sanctions, when they allegedly lobbied on behalf…
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…
OFAC FAQs: The End or Beginning of Your OFAC Inquiry?
I hate knocking the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) for the guidance they…