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Sanction Law

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Erich Ferrari

Latest from Ferrari & Associates

Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) identified Consorcio Venezuelano de Industrias Aeronauticos y Servicios Aereos, S.A. (“Conviasa”) as blocked due to its being a part of the Government of Venezuela. As readers of this blog may known, the Government of Venezuela is blocked pursuant to E.O. 13884. The action taken last week also involved the identification for blocking of a number aircraft which comprised Conviasa’s…
It has been a while since we have posted, but we’re back by popular demand (actually, just one person’s polite request), and will try to begin posting on Sanctionlaw more often in 2020. We start off these renewed efforts by looking at OFAC’s recent designation of two senior officials of the Government of South Sudan. Today, the United States Department the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the designations of the Minister of…
The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has been busy over the past few weeks. First, a couple of weeks ago, they issued the amended Reporting, Procedures, and Penalties Regulations, 31 C.F.R. Part 501, which expanded the level of detail required for OFAC blocking and reject reports, and extended the requirement of reject reporting to non-financial institutions. Then on July 1, 2019, OFAC sent out a reminder that the…
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Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of a Finding of Violation (“FOV”) to State Street Bank and Trust Company (“State Street”) for violations of the Iranian Transactions and Sanctions Regulations (“ITSR”), also known the Iran trade embargo. According to OFAC, State Street processed 45 transactions over a three and a half year period related to pension payments made to a U.S. bank account…
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Today, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published “A Framework for OFAC Compliance Commitments” (“Framework”). In doing so, OFAC some what broke with tradition by providing detailed guidance on the key elements of an effective sanctions compliance program. In addition, they have highlighted some key considerations in regard to how the existence and nature of an OFAC compliance program can impact an enforcement matter, as well as highlighted…
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The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has discretion to both specifically license particular transactions, as well as broadly generally authorize–i.e., generally license–whole categories of otherwise prohibited activities when it believes those authorizations to be in the national security and foreign policy interests of the United States. One of the areas OFAC has traditionally used their discretion to generally license is the provision of legal services to or…
Every day, funds transfers are blocked by U.S. financial institutions and others due a belief that the blocking is necessary for compliance with U.S. economic sanctions regulations administered by the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). As readers of this blog may be aware, OFAC designates parties alleged to be engaged in activity that has been declared as contrary to U.S. national security and foreign policy interests under…
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As I have noted over the past year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has increasingly recently found itself defending its actions in U.S. District Court.  The latest lawsuit brought against OFAC was lodged by an Iranian entity, Fulmen Company (“Fulmen”), whose request for reconsideration of their designation under Executive Order (“E.O.”) 13382 was denied by OFAC on July 20, 2018.  There are two interesting aspects about the…
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Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Société Générale S.A. (“Soc Gen”) for violations of various OFAC administered sanctions programs. The OFAC settlement of $53,966,916.05 represented only a portion of a larger $1.3 billion amount Soc Gen is paying out to various authorities–including, the New York Department of Financial Services (“NYDFS”), the United States Department of Justice (“DOJ”), the Federal Board (“Fed”), and…
There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”)–the deal reached between Iran and a number of countries concerning the former’s much disputed nuclear program. For example, who would be put back on the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) Specially Designated Nationals and Blocked Persons List (“SDN List”)? Would the U.S.…