• OFAC Sanctions Three Members of a Powerful Honduran Family and their Bank
    On October 7, 2015 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it had made several
  • Navigators Insurance and The Importance of An OFAC Compliance Program
    OFAC Fines Navigators Insurance Company without Compliance Program for Apparent Violations of Various Sanctions Programs. Several interesting things stand out regarding OFAC’s
  • Can a Visit  To The New Cuban Embassy In Washington, DC Be Considered A Violation of U.S. Sanctions?
    After more than 53 years of hostility beginning with the outbreak of the Cuban revolution, diplomatic relations between the United States of
  • Vienna Agreement With Iran: New Opportunities For U.S. Companies?
    The Agreement concluded by the six world powers and the Islamic Republic of Iran in regard to its nuclear program, represents an
  • 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
  • GTO Issued Against 700 Businesses to Curb Money Laundering in Miami
    FinCEN: Geographic Targeting Order Issued Against ~700 Miami Businesses; Requires Implementation of Elevated Anti-Money Laundering Controls. On April 15, 2015, the U.S.
  • United States Creates a New Sanctions Program Designed to Deter Cyber Attacks
    On April 1, 2015 the President issued Executive Order 13694: Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities. 
  • 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
  • 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,
  • 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