Last September, I wrote about the designation by the Office of Foreign Assets Control (“OFAC”), under the Transnational Criminal Organization (TCO) program, of Paul Davis, Pac-Net and related entities along with a number of officers, directors and employees of those…
Security researchers have indicated that they have found Kim Jong Un’s pawprints all over the code used for the WannaCry ransomware, stolen from the CIA vaults by Vladimi Putin’s BFFs at WikiLeaks. This, of course, raises the question as to whether companies…
Way back in January of this year, I pointed out a problem that the Bureau of Industry and Security (“BIS”) and the Office of Foreign Assets Control (“OFAC”) may have unwittingly created for U.S. manufacturers of encryption-enabled products, i.e., virtually…
In an earlier post, I expressed some incredulity with respect to an dubious scheme cooked up by some Pennsylvania legislators to import Cuban rum without an OFAC license. The scheme was based on a questionable reading of Clause 2 of the…
The New York Times yesterday reported that it had, somehow or other, laid its hands on an administrative subpoena sent last December by the Office of Foreign Assets Control (“OFAC”) to Chinese telecom manufacturer Huawei. The subpoena, according to the…