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
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
Last month, the United States Court of Appeals for the D.C. Circuit issued an opinion in Chichakli v. Tillerson. For those of you unfamiliar with the litigation, Mr. Chichakli–who was formerly designated pursuant to E.O. 13348 (Liberia)–brought suit against the
If you’ve ever heard me speak at a conference or seminar on U.S. sanctions, then you’ll know one of my favorite sayings is: “when analyzing regulations administered by the United States Department of the Treasury’s Office of Foreign Assets Control
Just because you are a citizen of Iran does not mean that the Iranian Transactions and Sanctions Regulations (“ITSR”) prohibit U.S. persons from transacting with you. This statement is made in response to one of the most frequently asked questions
If you don’t watch the news, go on the internet, or have friends, then you probably haven’t heard of cryptocurrencies, such as Bitcoin, Ethereum, and Litecoin. While these digital assets have been around for years, they have recently gained increased
From what I understand the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), sends out over 1,000 administrative subpoenas every year. Many of these subpoenas go to companies and financial institutions that have the resources to
On August 17, 2017, the United States District Court for the District of Maryland issued a memorandum opinion granting in part and denying in part the parties’ cross-motions for summary judgment in the case of Dastranj v. Dehghan, a civil
Perhaps lost amidst the weekend’s news of Hurricane Harvey, Seb Gorka resigning, and Joe Arpaio being pardoned, was the announcement of a new Venezuelan sanctions authority, and several associated general licenses. While a new sanctions authority is always news around
