Apparently the National Security Division at DOJ had a bunch of interns this summer with nothing to do, because this is the only conceivable explanation for the mostly risible “Guidance Regarding Voluntary Disclosures” which the NSD released on October 2.…
On October 7, 2016, President Obama issued an executive order finding that the situation that led to national emergency declared in Executive Order 13047, and which led to the imposition of sanctions on Burma, had terminated. As a result of…
Several people have been wondering if I would write something about the allegation that Trump may have violated the Cuban embargo back in 1998. This blog expresses no opinion on political campaigns or figures, so I hesitate to wade into…
ABOVE: Paul Davis Yesterday, the Office of Foreign Assets Control (“OFAC”) designated PacNet Services, a Canadian payments processing company, and many of its officers and employees as SDNs under the Transnational Criminal Organization (TCO) program. According to OFAC’s press release,…
President Obama announced today, after meeting with the newly elected President of Burma, that he intends to lift all remaining sanctions on Burma. With unusual alacrity, at least for the Office of Foreign Assets Control (“OFAC”), that agency issued FAQ…