Could it Be? Are EU Sanctions Culpable in Failure of Food, Medicine Exports to Iran?
For over a year now, those in the sanctions policy and legal worlds have been discussing the difficulties that food…
Do Insurer’s Get Special Treatment in Sanctions Matters?
While I hesitate to say that the U.S. Government, or specifically the United States Department of the Treasury’s Office of…
CASE STUDY: Brokering Agricultural Commodities on Behalf of a Non-U.S. Person
A few months ago, we wrote a case study on how the United States Department of the Treasury’s Office of…
Does OFAC’s Policy on Licensing Release of Blocked Funds for SDN Reconsiderations Unfairly Limit U.S. Persons?
As I was reading back through the licensing policy statement of the United States Department of the Treasury’s Office of…
New Online OFAC Licensing Process on Its Way
So the rumor, which has recently been substantiated, is that the United States Department of the Treasury’s Office of Foreign Assets…
OFAC Kingpin Convicted for Drug Trafficking by a D.C. Jury
Last week Aurelio Cano Flores was convicted by a jury in Washington, D.C. for his involvement in the importation into…
OFAC Opens the Door for Funds Transferring Between Burma and the U.S.
On Friday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a general license authorizing…
Are Bank Compliance Officers Rendering OFAC Licensing Useless?
I have had some recent clients who we procured licenses from the United States Department of the Treasury’s Office of…
No OFAC License Needed for Payment of TRIA Judgment
This past week the United States District Court for the Southern District of New York ordered the payment of $359,689.75…
The Power of Paperwork
Economic sanctions regulations administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) change frequently.…