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 […]

End of Ivory Coast Sanctions

On September 14th, President Obama issued an Executive Order titled, “Termination of Emergency with Respect to the Situation in or in Relation to Cote d’Ivoire,” with respect to the situation in or in relation to Cote d’Ivoire or the Ivory Coast. This represents an official end to the Ivory Coast or Cote d’Ivoire Sanctions Program that […]

The End of Burma (Myanmar) Sanctions

On September 14th,  President Obama pledged to lift all of the economic sanctions against Myanmar or Burma. This was a broad regime-focused sanctions program that had been in place for almost two decades. In May of 1997, President Bill Clinton issued an executive order declaring a national emergency with respect to the actions and policies of […]

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 […]

OFAC Enforcement Trends

Since the beginning of August, there have been three publicly released enforcement actions by the Office of Foreign Assets Control (OFAC), including two within the same week. These enforcement actions are showing that OFAC is taking a close look at two different things: 1) the constant updating and updated screening of names on one’s list […]

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 […]