Tyler Cullis June 6, 2016 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…
Tyler Cullis April 5, 2016 Secretary Lew Gets All Aspirational But is he confusing these aspirations for Treasury's current practice?
Tyler Cullis February 22, 2016 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…
Tyler Cullis January 5, 2016 Congress Begins to Target President’s Licensing Powers Recently, some in Congress have expressed hostilities towards the President’s broad licensing powers under the International Emergency Economic Powers Act…
Tyler Cullis January 1, 2016 Negotiating the Future of Iran Sanctions, the White House Stumbles This past Wednesday, the Wall Street Journal reported that the United States was set to impose additional designations on certain…
Tyler Cullis December 31, 2015 2015 Year-in-Review: New Developments in U.S. Sanctions 2015 brought new opportunities and new challenges in the sanctions world. The most interesting developments, however, start and end with…
Tyler Cullis December 28, 2015 Are US Companies at Peak Interest in Iran? While U.S. law continues to prohibit most activities involving Iran, U.S. companies will remain even more put-off by the perceived…
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…
Tyler Cullis September 16, 2015 Carly Fiorina & The Trials of Foreign Subsidiaries Doing Business in Iran Who knew with both the advent of a nuclear accord between the U.S., other major world powers, and Iran and…
Tyler Cullis July 29, 2015 Iran Deal: Will Foreign Subsidiaries of US Parents Get General License Authorization? In a recent post, Sam discussed the open question of whether – pursuant to § 5.1.2 of Annex II of…