Sanction Law
Your Guide to the Office of Foreign Assets Control

Sanction Law is a resource for those seeking information on OFAC administered sanctions programs. This blog tracks the latest developments in the field of U.S. economic sanctions, offers commentary on their practical applications, and serves as a community for discussion on OFAC related matters.

For information on EU sanctions, check out the European Sanctions Law and Practice Blog European Sanctions Law and Practice Blog

In April 2013, the words “Office of Foreign Assets Control” appeared on the E! News website. While initially this strange clashing of worlds was feared to be a sign of the apocalypse, further investigation revealed it to be the result … Continue reading

In a surprising and unexpected move, OFAC has abruptly changed its six year-old policy regarding what constitutes a blocked person under U.S. sanctions.  The revised policy centers on what is referred to as the “50 Percent Rule,” the threshold under which … Continue reading

We don’t talk too much about North Korea on this blog. Frankly, there isn’t a lot of movement in that program, except for the occasional designations update. That said, this past week was a pretty big one for North Korea … Continue reading

On June 8, I posted an article related to the Fokker Services (“Fokker”) criminal case pending in the United States District Court for the District of Columbia. In that article, I detailed the factual basis underlying Fokker’s criminal conduct, and … Continue reading

This past March, President Obama issued Executive Order (E.O.) 13662, targeting those parties dealing in certain sectors of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State. Such … Continue reading

One of the great ironies you witness over and over again when you practice in the field of U.S. economic sanctions, is that the implementation of the regulations administered by the United States Department of the Treasury’s Office of Foreign … Continue reading

July 2014 will go down as the month The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) did some major housekeeping. In the last week or so, OFAC has issued three new sets of regulations. Not … Continue reading

This past Tuesday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and reissued the Burmese Sanctions Regulations in their entirety. This was done to implement a series of executive orders stretching as far back … Continue reading

Over the course of my career, I have been blessed to have had the opportunity work with companies and individuals around the world, many of which have been located in the Persian Gulf countries. Given the impact of U.S. sanctions … Continue reading

Since last November when the the P5+1 entered into the Joint Plan of Action (“JPOA”) with Iran concerning Iran’s disputed nuclear program, there has been a great deal of interest in the portion of the JPOA’s sanctions relief dealing with … Continue reading