OFAC Issues Updated JCPOA-Related FAQs
It was long rumored that the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) would issue a…
Secretary Lew Gets All Aspirational
But is he confusing these aspirations for Treasury's current practice?
Is The “Spirit” of Sanctions The Law?
Do sanctions have a "spirit"? U.S. sanctions officials seems to think so, as they argue that it is not enough…
FinCEN Withdraws Section 311 Designation for BPA
Word of advice: Don’t get labeled a foreign financial institution of primary money laundering concern because it will be a…
Ghostwriting El Chapo’s Memoirs is a Bad Idea
In the wake of the now-infamous Sean Penn interview, The New Yorker’s Patrick Radden Keefe writes a fascinating tale of…
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…
Are U.S. Sanctions Targeting Iran Working?
The big news of this weekend was that Iran has stated it is willing to engage in direct talks with…