Erich Ferrari June 3, 2019 Common Problem, Uncommon Consequence: The State Street Bank and Trust OFAC Enforcement Matter Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of a…
Erich Ferrari December 22, 2017 You Talking to Me? The ITSR, Iranians, and Ordinary Residency Just because you are a citizen of Iran does not mean that the Iranian Transactions and Sanctions Regulations (“ITSR”) prohibit…
Erich Ferrari November 10, 2011 New OFAC Civil Penalties Announced Yesterday, the United States Department of the Treasury Office of Foreign Assets Control (OFAC) announced the settlement of two matters…
Erich Ferrari March 19, 2010 Voluntary Self Prosecution It is well known that the United States Department of the Treasury Office of Foreign Assets Control (“OFAC”) will mitigate…