• April 23, 2024

The Only Comprehensive Resource on U.S. Economic Sanctions

Category : Ferrari Legal, P.C.

CASE STUDY: Sale of Shares in an SDN Entity

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/case-study-sale-of-shares-in-an-sdn-entity/"></div>Recently, we had an opportunity to successfully represent a private individual who held assets in an Iranian entity obtain a license from the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC). While this is not uncommon, the twist in this case was that the entity was a Specially Designated National (SDN) […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_

One Reason Why Foreign Financial Institutions Might Be Blocking CBI’s

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/one-reason-why-foreign-financial-institutions-might-be-blocking-cbis-funds/"></div>For nearly two (2) years, we have received numerous questions regarding amounts frozen in the bank accounts of foreign financial institutions that belong to the Central Bank of Iran (CBI). Typically, these funds which have been frozen are revenues for the purchase of Iranian-origin oil, and the reasons cited for the blocking are U.S. sanctions. […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_

OFAC Goes Back After Caro Quintero

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-goes-back-after-caro-quintero/"></div>Rafael Caro Quintero hasn’t been out of jail for three (3) months, and yet the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) is already back on the case. Caro Quintero was designated pursuant to the Foreign Narcotics Trafficking Kingpin Designation Act (“Kingpin Act”) in 2000, making him one of the […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_

OFAC Seeks to Break Up Brothers’ Circle

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-seeks-to-break-up-brothers-circle/"></div>Today, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the designation of six (6) individuals and four (4) entities belonging to the Brothers’ Circle, an alleged international criminal organization operating in the Middle East, Africa, and the Americas. OFAC’s designation, made pursuant to Executive Order (E.O.) 13581 and the […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_

Another U.S. Subsidiary of a Foreign Parent Company Leads to

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/another-u-s-subsidiary-of-a-foreign-parent-company-leads-to-ofac-penalty/"></div>There is always a lot made of U.S. companies being subjected to liability for sanctions violations for the actions of their foreign subsidiaries. One fairly common occurrence that does not get as much attention, however, is that of foreign companies being subjected to liability for sanctions violations as a result of the activities of their […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_

The Hangover: OFAC Targets Mexican Tequila Maker

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/the-hangover-ofac-targets-mexican-tequila-maker/"></div>Earlier this week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on a Mexican tequila company that has allegedly been involved in the laundering of funds on behalf of the Los Gueros organization. The tequila company targeted, El Viejo Luis, was among five companies accused of laundering funds […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_

OFAC General License D: Is the “D” for Deceiving?

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/ofac-general-license-d-is-the-d-for-deceiving/"></div>Before any officials of the Office of Foreign Assets Control (“OFAC”) or any other U.S. agency takes this post the wrong way, let me provide a disclaimer: I do not intend to suggest that the U.S. Government has deceived the public as to its good intentions in issuing General License D which allows for the […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on

With Two New General Licenses Is OFAC Attempting to Restore

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/with-two-new-general-licenses-is-ofac-attempting-to-restore-balance-to-the-force/"></div>Today, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of two (2) general license authorizations in relation to Iran. The first general license, General License E, authorizes the exportation of services and funds transfers by nongovernmental organizations in support of certain not-for-profit humanitarian activities designed to benefit […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_

More NDAA 1245 Waivers Issued By U.S. Government

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/more-ndaa-1245-waivers-issue/"></div>On Friday, the United States announced that it had extended sanctions waivers to ten (10) European Nations and Japan due to their decreasing oil imports from Iran. Of those receiving such waivers, Japan is the only country still importing oil from Iran. As a result of these waivers, foreign financial institutions in those countries will […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_the_

How Should Foreign Financial Institutions Treat Executive Order 13608 Designees

<div class="at-above-post-cat-page addthis_tool" data-url="https://sanctionlaw.com/how-should-foreign-financial-institutions-treat-executive-order-13608-designees/"></div>Sometimes forgotten in the long and growing list of Executive Orders directing sanctions to be imposed against various alleged bad actors, is Executive Order (E.O.) 13608 which prohibits certain transactions with, and suspends entry to, the United States of foreign sanctions evaders with respect to Iran and Syria. Just as the name suggests, E.O. 13608 […]<!-- AddThis Advanced Settings above via filter on get_the_excerpt --><!-- AddThis Advanced Settings below via filter on get_