Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it was issuing two revised general licenses issued under the Venezuela Sanctions Regulations (“VSR”), 31 C.F.R. Part 591, and made conforming changes to two
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OFAC Continues Iran Designations Despite COVID-19 Outbreak
Despite most of the world being in self-quarantine mode to prevent the spread if COVID-19, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)–as well as the United States Department of State–have continued their work of
Conviasa: Is OFAC Closing the Cabin Door?
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.
South Sudan Sanctionable
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
Observe and Report: OFAC Issues Reminder on Annual Blocked Property Reports
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,
Common Problem, Uncommon Consequence: The State Street Bank and Trust OFAC Enforcement Matter
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
Framed: OFAC Sets Out Expectations for Compliance with U.S. Sanctions
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
The Evolution of OFAC General Licenses for Legal Services
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
Three Tips for Filing an OFAC License Application to Unblock Funds
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
Fulmen Company v. OFAC: It Looks Like Everyone’s Going to Lose
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