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Blocked Entity Guidance

OFAC’S Blocked Entity Guidance Appears in South Sudan-Related Sanctions FAQ

June 17, 2014

OFAC’s recent activity re: the South Sudan-related sanctions program reaffirms its “affirmative determination” opinion highlighted in our last blog post.

Recent Case Results

OFAC Unblocking License Obtained for SDN False Positive Match

Price Benowitz’s OFAC Law Group successfully obtained an OFAC unblocking license for a client whose personal funds were blocked due to an intermediary financial institution’s false positive match to the Specially Designated Nationals List. The client’s name resembled a person on the SDN list and the funds were blocked due to a lack of timely […]
Specific License Granted for Payment from SDN List Client

The OFAC Law Group was granted an OFAC specific license to obtain payment from an SDN client. The payment structure fell outside of the authorization of the general license to receive legal fee payments from an SDN person. Law firms must review the limitations of relevant authorizations to receive payment from SDN persons. SDN list […]
Breaking False Claims Act News: Qui Tam Settlement Reached

While the defendants did not admit any fault, we are happy to report that PAE agreed to pay the United States $5,000,000 to resolve the False Claims Act allegations contained in Mr. Palombo’s Complaint.

Latest blog posts

What’s Going to Happen with Exports of Commercial Drones?

In 2015, many believed to have seen an announcement by the Department of State relaxing drone exports, but a close look at the announcement suggests otherwise. According to a publication by the Directorate of Defense Trade Controls, “The FAA Modernization and Reform Act of 2012 for Unmanned Aircraft Systems (http://www.hse-uav.com/faa_modernization_and_reform_act_2012.htm) creates a statutory basis for […]

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Trends in OFAC Enforcement

By Juhi Tariq – Which cases have been considered egregious? AIG Case – June 26, 2017 Though the transactions totaled almost double the amount, OFAC’s base penalty for AIG was $198, 226. Mitigating factors: No prior penalty notice or Finding of Violation from OFAC in the past five years Existence of a compliance program that […]

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Russia Sanctions Bill Signed

From NYT: President Trump signed legislation on Wednesday imposing sanctions on Russia and limiting his own authority to lift them, but asserted that the measure included “a number of clearly unconstitutional provisions” and left open the possibility that he might choose not to enforce them as lawmakers intended. In particular, he objected to Congress interfering with the […]

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