Erich Ferrari October 24, 2012 OFAC Revises 31 CFR Part 560 as the Iranian Transactions and Sanctions Regulations (ITSR) Yesterday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a significant revision of 31 CFR…
Erich Ferrari June 19, 2012 Peeling Back the Onion: Can the U.S. Grant Sanctions Relief During the Nuclear Talks? One of the big sticking points between Iran and the United States during the latest round of talks over Iran’s…
Erich Ferrari May 21, 2012 $112,500 Settlement for Iran Sanctions OFAC Violations Today, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that Genesis Assets Managers, LLP…
Erich Ferrari March 26, 2012 OFAC Amends the Iranian Transactions Regulations Last week the United States Department of the Treasury’s Office of Foreign Assets Control (‘‘OFAC’’) amended the Iranian Financial Sanctions…
Erich Ferrari March 6, 2012 Facilitation Under OFAC Administered Sanctions Programs One of the least understood and most confusing concepts for those dealing with matter before the United States Department of…
Erich Ferrari January 12, 2012 OFAC Penalties Significantly Decreased in 2011 Sometime last year, I wrote a blog posting pontificating about a reduction in OFAC civil penalties and that the era…
Erich Ferrari July 14, 2011 How to Make Sense of the Iranian Bank Account Question A big part of addressing any question related to a transaction impacted by a sanctions program administered by the United…
Erich Ferrari June 1, 2011 Debunking the Myth: Transfers of Less than $10,000 Can Be “Smurfing” There is a prevailing myth amongst many people that if you transfer money in amounts of less than $10,000 from…
Erich Ferrari May 14, 2011 Should You Request a Reconsideration of Your Denied OFAC License Application? When the United States Department of the Treasury Office of Foreign Assets Control (OFAC) denies your license request it can…
Erich Ferrari May 5, 2011 To Reject or To Block, That is the OFAC Question A number of people have come to us recently inquiring into whether or not a funds transfer will be blocked…