Category OFAC

Heads We Win; Tails You Lose

Well, Implementation Day has come and gone.  Hassan Rouhani peeked out of his house, did not see his shadow, and his handlers declared that winter would soon be over … at least if you’re in Europe.  If you’re in the United States,…

Writing Regulations Is Hard

In late December, the Office of Foreign Assets Control (“OFAC”) updated its Cuba FAQs to add questions #57-61 on insurance issues.  Naturally, there is no explanation for why these were added but if you supposed that they were added to…