Risky Business: No Guidance On Secondary Sanctions Liability
As the number of secondary sanctions authorities at the disposal of the United States Department of the Treasury’s Office of…
OFAC’s New Math: 25+25 = SDN
In a surprising and unexpected move, OFAC has abruptly changed its six year-old policy regarding what constitutes a blocked person under…
A North Korean State Of Mind
We don’t talk too much about North Korea on this blog. Frankly, there isn’t a lot of movement in that…
OFAC Takes A New Approach: Russian Sectoral Sanctions
This past March, President Obama issued Executive Order (E.O.) 13662, targeting those parties dealing in certain sectors of the Russian…
When Drones Fail, The US Government Calls In The Big Dogs
Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control announced the designation of Shawki Ali Ahmed…
Meta OFAC: Appeals And Renewed SDN Requests For Reconsideration
One of the most frustrating aspects of practicing law in the area of U.S. economic sanctions is explaining to clients…
Smoke On The Horizon: Lobbyists, Retainers, And Russia
Last week, The Hill reported that lobbyists representing the interests of Russian President Vladmir Putin in the United States have…
OFAC Targets Yakuza Affiliates In Latest Designations
Shortly before the holidays the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated a number…
Representing SDNs And How Counsel Of Choice May Disappear
I have previously written on the difficulties of representing Specially Designated Nationals and Blocked Persons (“SDNs”) due to issues concerning…
The Rise Of OFAC Compliance Clauses
“OFAC” clauses are becoming more and more common in today’s trading agreements. These clauses set forth how the agreement will…