After more than 53 years of hostility beginning with the outbreak of the Cuban revolution, diplomatic relations between the United States of America and the Cuban government are going to be restored.[1] The normalization of the relationships between the two countries began on December of last year and culminated on April 2015 when, for the […]
OFAC
The U.S. Secondary Sanctions System
Impact on European Banks and Companies The American sanctions system against the Islamic Republic of Iran found its origins some years after the outbreak of the Iranian Revolution of 1979, becoming more restrictive in 1995 when President Clinton (see right) prohibited U.S. persons and entities from engaging in most transactions with Iran.[1] These restrictions concerned […]
Indicted, Extradited, and Sanctioned
Legal & Practical Challenges to Representing Alleged Foreign Narcotics Traffickers Foreign nationals face several unique challenges when forced to appear in the United States to face allegations that they are narcotics traffickers. Many foreign nationals facing extradition to the United States for narcotics trafficking have been indicted by at least one grand jury. The grand […]
Syria Sanctions: OFAC Issues New General License Authorizing Publishing-Related Transactions
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) commonly issues general licenses to sharpen and fine tune its country-based sanctions programs to minimize unintended consequences. On April 13, 2015, OFAC issued a new general license in the Syrian Sanctions Regulations, promulgated pursuant to Executive Order 13338. This new general license authorizes […]
Executive Order Authorizes OFAC Targeting of Venezuelan Officials
Executive Order 13692: Expands Upon Congressional Legislation; Authorizes OFAC To Designate Venezuelan Officials for Their “Status,” Not Their “Conduct.” Like many sanctions programs before it, the Venezuela-related OFAC sanctions program is implemented pursuant to the International Emergency Economic Powers Act (IEEPA). However, one unique aspect of this sanctions program is that it is also implemented […]
Judge Leon: DPA “Grossly Disproportionate” To Fokker’s Conduct Violating OFAC Sanctions
In a rare rebuke of the executive branch’s discretionary authority in enforcing economic sanctions, U.S. District Court Judge Leon sent Fokker Services, B.V.,
OFAC Sanctions & Family Law: An Odd Coupling of Practice Areas
My law offices are often contacted by people in the midst of a family law dispute. These calls have been from people in the midst of divorce, contract disputes, and contested probate
President Obama Announces Major Breakthrough in US-Cuba Relations
On December 17, 2014 President Obama announced historic steps his administration will take to usher in a new, more inclusive era of US-Cuba relations.
De-banking MSBs: Damned If You Do, Damned If You Don’t?
On November 10, 2014 the Financial Crimes Enforcement Network (FinCEN) issued a statement encouraging the provision of banking services to Money Services Businesses (MSBs) …
OFAC SDN List Removal: Deutsche Forfait’s Successful De-Listing Petition
On February 6, 2014 DF Deutsche Forfait AG received the dreaded news that it was placed on the Specially Designated Nationals and Blocked Persons List (SDN List) administered by OFAC.