Erich Ferrari November 13, 2015 See You At The Crossroads: OFAC Says Goodbye to an Old Friend Executive Order 13348 had a good run. But when the United Nations rescinded Security Council Resolution 1521 earlier this year,…
Tyler Cullis November 10, 2015 The Return of the General License: Authorizing the Importation of Iranian-Origin Carpets and Foodstuffs As is clear by now, the nuclear agreement between the United States, other major world powers, and Iran will herald…
Tyler Cullis November 2, 2015 Guidance on Iran Sanctions Relief is Coming Sooner Than Later I’ve been getting a lot of questions recently as to when we can expect OFAC to start issuing guidance related…
Margaret Ververis October 30, 2015 Gil Travel Enforcement Action Teaches Lesson About Compliance On October 27, 2015, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a web…
Shahroo Yazdani October 22, 2015 OFAC Et Le Monde: Credit Agricole Violation Yet another French bank finds itself entangled with the Office of Foreign Assets Control (OFAC). On Tuesday, OFAC published it’s…
Samuel Cutler July 8, 2015 Senate Fails the Belichick Test, Won’t Confirm Adam Szubin It has been almost three months since President Obama formally nominated Adam Szubin as Undersecretary for Terrorism and Financial Intelligence…
Samuel Cutler July 6, 2015 Those Who Cannot Remember the Past Are Condemned to Repeat It: Iran Edition As the deadline for a comprehensive agreement approaches, many companies are salivating at the prospect of a sanctions-free Iran. With…
Samuel Cutler June 11, 2015 Iran, U.S. Trade Warnings Over Mahan’s New Airbuses In the latest installment of the Mahan Air/Al-Naser Airlines saga, officials from both the U.S. and Iran have begun exchanging…
Erich Ferrari May 17, 2015 Watch Your 602: OFAC Administrative Subpoenas and Non-U.S. Persons If you have any experience dealing with OFAC, the United States Department of the Treasury’s Office of Foreign Assets Control,…
Samuel Cutler February 24, 2015 Treasury [Does Not] Want to Pump You Up When a Kingpin designation notice from Treasury pops up in your inbox, the first thought in your mind is not…