• Extension of Limited Iran Sanctions Relief Includes Civilian Passenger Aircraft Parts
    On July 19, 2014 the United States and its partners in the P5+1 (China, France, Germany, Russia, the United Kingdom, and the
  • Will OFAC Respond to Stalled Democratic Reform in Burma?
    Current crisis could spur OFAC to re-implement some, if not all, of the economic sanctions lifted in 2013. Since at least last
  • Largest Settlement for OFAC Violations
    According to the Department of the Treasury, its Office of Foreign Assets Control (OFAC) has reached the largest ever settlement, totaling $963
  • Smurfing and OFAC
    Originally Published June 10, 2014 How Your Under-$10,000 Transactions Can Actually Raise Your Profile for Investigations by the Feds Whenever a U.S.
  • OFAC Lifts Remaining Sanctions on the Cali Cartel
    308 NAMES REMOVED FROM THE SDN LIST IN SINGLE LARGEST ACT OF DELISTING OFAC announced today that it has removed the names of over
  • OFAC’S Blocked Entity Guidance Appears in South Sudan-Related Sanctions FAQ
    Originally Published June 5, 2014 OFAC's recent activity re: the South Sudan-related sanctions program reaffirms its "affirmative determination" opinion highlighted in our last blog post.  In that
  • Russia Sanctions: Is OFAC Flip-Flopping on its Blocked Entity Guidance?
    Originally Published May 27, 2014. An interesting Russia sanctions revelation was made in the most recent chapter of the SpaceX bid protest
  • Foreign Sanctions Evaders and St. Kitts and Nevis
    Originally Published May 21, 2014 Yesterday, the Financial Crimes Enforcement Network ("FinCEN") issued an Advisory "to alert financial institutions that certain foreign individuals are
  • Burma Sanctions: Will Backsliding on Reform Lead to Backsliding on Sanctions Relief?
    Originally Published May 20, 2014. Last Thursday President Obama notified Congress of his decision to continue the National Emergency with respect to Burma by
  • Sanctions, Justice, and Trade
    Originally Published May 15, 2014 The intersection of sanctions, criminal justice, and trade is something that I have thought about since I