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

This post may not be reaching the correct audience, but for those not aware, there’s an arm of the United States Department of the Treasury called OFAC, or the Office of Foreign Assets Control if you’re not into the whole … Continue reading

Yesterday, DF Deutsche Forfait AG (“Deutsche Forfait”), a German trade finance firm, issued a press release regarding their recent delisting from the United States Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) List of Specially Designated Nationals and … Continue reading

A Chicago jury has confirmed what all of us in the U.S. sanctions world should already know (I hope) – that lobbying representatives of state and federal legislatures on behalf of Specially Designated Nationals and Blocked Persons (“SDNs”) is not … Continue reading

Don’t call it a comeback. On Friday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) unleashed a number of designations targeting Iranian entities under a host of authorities for activities as broad ranging as support … Continue reading

As the number of secondary sanctions authorities at the disposal of the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) grows, many foreign entities who could become targets of those sanctions have, understandably, had serious concerns … Continue reading

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