Observe and Report: OFAC Issues Reminder on Annual Blocked Property Reports
The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has been busy over the past few…
Shock Gen: The Dangers of the OFAC Voluntary Self-Disclosure
Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Société…
They’re Ba-ack….JCPOA Withdrawal Nearing Completion with E.O. 13846
There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from…
OFAC Takes Aggressive Action Against Venezuela
On May 18, 2017, acting pursuant to Executive Order 13692, OFAC designated eight members of Venezuela’s Supreme Court of Justice…
Inaugurating the Terrorist Financing Targeting Center
The United States has entered a historic agreement with its Gulf Arab partners to target terror finance networks. But is…
President Amends Cyber Sanctions Executive Order, Sanctions High-Level Russian Government Targets
On December 29, 2016, President Obama amended Executive Order 13694 – otherwise known as the ‘Cyber Sanctions Executive Order’ –…
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…
Three Tips for Responding to OFAC Administrative Subpoenas
It’s been a long time since I’ve written a “how to” piece on SanctionLaw–or anywhere else for that matter. However,…
OFAC’s Interpretive Guidance Can Prove Dated
One thing we should all be able to agree on is that the interpretive guidance OFAC publishes should be consistent…
It was a Bad Week for the Waked MLO
Lsat week, OFAC designated the Waked Money Laundering Organization, its leaders and associates, and 68 companies tied to it under…