The Evolution of OFAC General Licenses for Legal Services
The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has discretion to both specifically license particular…
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…
The 800 lb. Gorilla in the Room: OFAC and Facilitation
There is one word that makes practitioners before the United States Department of the Treasury’s Office of Foreign Assets Control…