CASE STUDY: Sale of Shares in an SDN Entity
Recently, we had an opportunity to successfully represent a private individual who held assets in an Iranian entity obtain a…
OFAC Goes Back After Caro Quintero
Rafael Caro Quintero hasn’t been out of jail for three (3) months, and yet the United States Department of the…
OFAC Seeks to Break Up Brothers’ Circle
Today, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the designation of six (6)…
How Should Foreign Financial Institutions Treat Executive Order 13608 Designees
Sometimes forgotten in the long and growing list of Executive Orders directing sanctions to be imposed against various alleged bad…
OFAC Goes Silent on Iran
In the lead-up to Iran’s elections on June 14, 2013, The United States Department of the Treasury’s Office of Foreign…
Burma…Going….Going…But Not Yet Gone
Last week, President Obama, in light of the expiration of the Burmese Freedom and Democracy Act’s (BFDA) import ban issued…
OFAC Designations and the Right to Effective Assistance of Counsel
In recent months, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) has engaged in a…
Iran Sanctions Bonanza: New Designations and Legislation
With the Iranian Presidential elections exactly one month away the U.S. has taken the opportunity to ratchet up sanctions on…
SDNY Strikes Again: A Kingpin Has Arrived In America
Last week the United States Attorney’s Office for the Southern District of New York (USAO SDNY) announced the extradition of…
OFAC OGT Gets Busy Removing Kingpins from SDN LIst
Today, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that they were removing 12…