Decertifying the Iran Deal

President Trump must make a decision prior to October 15th on the certification of the Iran Nuclear Deal or Joint Comprehensive Plan of Action (JCPOA) that was implemented in January 2016. If it were decertified, the onus would be on the U.S. Congress to decide in 60 days whether to impose nuclear-related sanctions that were […]

New UN Security Council Sanctions and Current OFAC Sanctions on North Korea

On September 12th 2017, the Security Council passed, in a unanimous 15-0 vote, new economic sanctions against North Korea. These sanctions added an extra layer of international restrictions on the already isolated regime. The basis of the sanctions was drafted by the United States and after compromise with China and Russia were weakened just enough […]

President Trump Announces Changes to Cuba Sanctions Program

On June 16, President Trump announced two impending, significant changes to the Cuba sanctions program, which will impact U.S. persons traveling to Cuba. In general, to travel to Cuba a U.S. person must fit within one of 12 categories authorized by OFAC. Individual people-to-people travel, which was under the general category of educational activities and […]

President Obama Sanctions Russian Entities and Individuals for Tampering with Election

On December 29, 2016, President Obama took action to expand the scope of the Department of the Treasury’s Cyber-related Sanctions Program to include, among other things, tampering with election processes.  Specifically, the President issued an Executive Order, Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities. This Executive Order […]

Did Trump Violate the Cuba Sanctions?

Newsweek broke a story that Donald Trump’s company may have violated the Cuban Assets Control Regulations (CACR). Specifically, Newsweek claims that “[d]ocuments show that the Trump company spent a minimum of $68,000 for its 1998 foray into Cuba at a time when the corporate expenditure of even a penny in the Caribbean country was prohibited without U.S. government approval.”

Eliminating Terrorist Financing Without Damaging Legitimate Transactions

Eliminating Terrorist Funding while Enhancing Legitimate Commercial Transactions and Family Remittances There is consensus that financing terrorism, via the international financial system, must be systematically eradicated while maintaining channels for legitimate commercial and family-related financial transactions.  Unfortunately, many international banking conglomerates refuse to do business with certain countries altogether, as their costs of compliance outweigh […]

New OFAC Secondary Sanctions Against Hizballah

OFAC Issues Secondary Sanctions for Foreign Banks Doing Business with Hizballah On April 14, 2016, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new secondary sanctions (found in 31 C.F.R. 566 (pdf)) to implement the Hizballah International Financing Prevention Act of 2015. The new secondary sanctions target foreign financial institutions […]

A Closer Look at OFAC’s General License H

Back in July (2015) the permanent members of the UN Security Council (China, France, Russia, the United Kingdom, and the United States), Germany (collectively the P5+1), the European Union, and Iran reached a Joint Comprehensive Plan of Action (JCPOA) to ensure that Iran’s nuclear program would be exclusively peaceful.

OFAC Fines Barclays Bank Over Shadow Blocked Entities

Barclays Bank Pays Millions to Settle Sanctions Violations Involving Shadow Blocked Entities On February 8, 2016, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement between the agency and Barclays Bank Plc regarding apparent violations of the Zimbabwe Sanctions Regulations (ZSR). Specifically, Barclays (including its New York branch), processed […]