Erich Ferrari July 10, 2019 Observe and Report: OFAC Issues Reminder on Annual Blocked Property Reports The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has been busy over the past few…
Erich Ferrari June 3, 2019 Common Problem, Uncommon Consequence: The State Street Bank and Trust OFAC Enforcement Matter Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of a…
Erich Ferrari December 2, 2018 Shock Gen: The Dangers of the OFAC Voluntary Self-Disclosure Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Société…
Erich Ferrari December 18, 2017 Crypto-Craze: Will Sanctions Evaders Turn to Cryptocurrencies to Beat OFAC? If you don’t watch the news, go on the internet, or have friends, then you probably haven’t heard of cryptocurrencies,…
Erich Ferrari December 11, 2017 Factoring In OFAC’s Enforcement Guidelines From what I understand the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), sends out over…
Erich Ferrari July 3, 2017 Not Exactly a Line in the Sand: The D.C. Circuit and Attempt Liability Under the ITSR Admittedly, I’m late to the party on this, but as you likely already know the D.C. Circuit has issued its…
Erich Ferrari April 12, 2017 ZTE Case Highlights Problem with OFAC Enforcement Guidelines I like the General Factors Affecting Administrative Action. I really do. If you don’t know what I’m talking about, allow…
Erich Ferrari January 16, 2017 IEEPA: So Easy Even a Caveman Can Understand It Here goes my sour grapes post. There have been a number of motions to dismiss filed by defendants in criminal…
Erich Ferrari December 13, 2016 Is Epsilon Electronics the Donald J. Trump of OFAC Enforcement Cases? I’m going to have to pick up a new hobby once the United States Court of Appeals for the District…