More Screening Nightmares
I think more needs to be said about OFAC’s greater than 50 percent rule which was covered in yesterday’s post. As you recall, the rule in question says that if a blocked party owns more than 50 percent of another…
Clif Burns
People Are from Earth; OFAC Is from Saturn
The latest technical amendments promulgated last Friday by the Office of Foreign Assets Control (“OFAC”) make me wonder where the people who write these rules come from. Mars, perhaps? No, further out. I’m guessing they come from Saturn because even…
Just What We Need: More Export Controls
The Senate Armed Services Committee has favorably reported S. 1197, the National Defense Authorization Act for Fiscal Year 2014. And, you will be pleased to know (or maybe not), they have slipped into the bill a proposal for new export…
What Do These Two People Have in Common?
Indeed, what do former House Majority Leader Richard Armey and former Beatle Ringo Starr have in common? Other than, of course, immense artistic talent and devilish good looks. Well, they both are named Richard and they both were born on…
OFAC v. ATP: Game, Set, Match to OFAC
In its quest to keep the world safe from an Iranian nuclear bomb, the Office of Foreign Assets Control has focused its laser-like scrutiny on an Iranian tennis referee. Obviously, the same skills required to call a ball out or…