U.S. Senators Kirsten Gillibrand (D-NY) and Mark Kirk (R-IL), and U.S. Representatives Ted Deutch (D-FL) and Dan Burton (R-IN) today introduced the Iran Transparency and Accountability Act designed to strengthen U.S. unilateral sanctions against Iran. Although the text of the…
Trans Pacific National Bank recently agreed pay $12,500 penalty to the Office of Foreign Assets Control (“OFAC”) to settle charges that it had facilitated transactions by a foreign person where the transactions by the foreign person would be prohibited if…
Iran sanctions seem to be all in the news this week, particularly with respect to who is and who isn’t selling stuff to Iran. The Wall Street Journal ran an opinion piece that suggested that although Germany talks a good…
At last, on Christmas Eve, a federal holiday, the New York Times finally releases its analysis of documents it received from the Office of Foreign Assets Control (“OFAC”) as a result of its Freedom of Information Act request relating to…
Dandle, to most of you, is a verb meaning to dance a small child up and down on one’s knee. Others, particularly regular readers of this blog, will recognize it as the surpassingly odd name of an Islamic Republic of…