Oh No, Is OFAC Going After Attorneys???
Last week I was speaking with a friend of mine who serves as inside counsel on sanctions at a major…
New GAO Report Provides Much-Needed Accounting
Last week, the GAO released a report that provides some much-needed accounting as to the sums that OFAC and other…
Is The “Spirit” of Sanctions The Law?
Do sanctions have a "spirit"? U.S. sanctions officials seems to think so, as they argue that it is not enough…
North Korea Sanctions Get Upgraded, But Will They Work?
Last week, President Obama signed into law the North Korea Sanctions and Policy Enhancement Act of 2016, which sharply expands…
Is OFAC Warning Off Foreign Banks from Iran?
In an explosive piece published this past weekend, the Financial Times alleges that OFAC may still be warning off foreign…
Iran Reconnects to SWIFT, But Does It Matter?
The big question is whether Iran’s banks will be able to consummate correspondent banking relations with global financial institutions in…
OFAC’s Iran Sanctions Guidance Is Imminent
Sometime between now and next week, OFAC will release detailed guidance relating to sanctions-relief on Iran. Whether it succeeds or…
OFAC Inaugurates the Cyber-Related Sanctions Regulations
On December 31, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) inaugurated the much-anticipated ‘Cyber-Related…
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…
Ready, Set, Wait: How You Can Predict Receiving an OFAC Administrative Subpoena or Grand Jury Subpoena
One of the most underreported aspects of the recent cases concerning banks being investigated and penalized by regulators–including the United…