I’m not sure that chutzpah is a term applicable to government agencies, but, if it is, this is chutzpah. The International Trade Commission announced that it is investigating how Cuban non-tariff measures, Cuban institutional and infrastructural factors, and other Cuban…
A recent article in the Miami Herald discussed the bureaucratic entanglements involved when world-famous athlete Diana Nyad wanted to make a historic swim between Florida and Cuba. She needed an OFAC license to visit Cuba. Her support team needed a…
An article in today’s Washington Post may be attracting some attention over in the halls and cubicles of the Office of Foreign Assets Control (“OFAC”). It describes in some detail how Miles Jackson, a local DC man and skateboarding enthusiast,…
U.S. sanctions on Iran make a number of benign transactions with Iran difficult. If you want to send, say, a chia “pet” to a relative in Tehran, you need a license, and you probably can’t get one. On the other…
The saga of the over-reaching New York Department of Financial Services (“NYDFS”) and Standard Chartered Bank, chronicled on this blog here, here, and here, is the blogging gift that just keeps on giving. Standard Chartered Bank hired Promontory Financial Group…