The just-passed Iran Sanctions, Accountability, and Human Rights Act of 2012 for the most part merely decorates the Iran sanctions cake with a few more sprinkles and cherries, but one provision is likely to have a significant impact, namely the…
Yesterday, I reported on the New York Department of Financial Services’ Order against Standard Chartered claiming that the Bank violated the rules of the Office of Foreign Assets Control by stripping out the names of Iranian entities in wires for…
Here’s a good rule of thumb: Write all emails as if the distribution list included the entire planet because you never know when any given might come back to haunt you. If a certain executive at Standard Chartered had followed…
Back in 2009, this blog reported on the arrest of Chi Tong Kuok, a PRC citizen, during a layover in Atlanta while he was traveling to Panama to meet with undercover agents who believed he was involved in various illegal…
The Office of Foreign Assets Control (“OFAC”) today applied sanctions under the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010 against the Bank of Kunlun in China and the Elaf Islamic Bank in Iraq. Under these sanctions, U.S. financial…