Last week I posted on the new Somalia “smart” sanctions and noted that the concerns by the maritime industry that the new sanctions would prohibit ransom payments were unfounded. The industry was concerned that language in the executive order, which…
It is not only birds that return in springtime. Calmer weather on the Indian Ocean guarantees a springtime efflorescence of Somali pirate skiffs and attacks on commercial shipping off the coast of Somalia. Pirates have already grabbed a supertanker (with…
SEE IMPORTANT UPDATE AT THE END OF THIS POST The headline to this post — “Voluntary Disclosure Leads to Criminal Prosecution” — will probably send a chill down the spine of every export and sanctions lawyer who reads this post.…
My colleague Stan Marcuss points out that the Office of Foreign Assets Control (“OFAC”) appears to have changed course in treating Freedom of Information Act (“FOIA”) requests and has decided to hand out OFAC license applications willy-nilly to anyone who…
An interesting story in today’s Wall Street Journal details instances in which a number of U.S. companies imported items from China Precision Machinery Import Export Corporation despite the fact that CPMIEC is on the Office of Foreign Assets Control’s Specially…