Another Way Cigars Are Bad for You
If for some reason or other you were thinking that perhaps the next time you were in Dunhill’s in Paris or London you might just slip a few Cubans into your briefcase and bring them back to the U.S., think…
Another Exporter Trips over the Entity List
Two weeks ago I reported on a settlement agreement between two shipping companies and the Bureau of Industry and Security (“BIS”) with respect to unlicensed exports of scrap steel to People Steel Mill, a company in Pakistan on BIS’s Entity…
New Law Eliminates Foreign Sub Loophole in Iran Sanctions
The just-passed Iran Sanctions, Accountability, and Human Rights Act of 2012 for the most part merely decorates the Iran sanctions cake with a few more sprinkles and cherries, but one provision is likely to have a significant impact, namely the…
OFAC to UK: NYDFS Misread Our Rules
Yesterday, I reported on the New York Department of Financial Services’ Order against Standard Chartered claiming that the Bank violated the rules of the Office of Foreign Assets Control by stripping out the names of Iranian entities in wires for…
You Won’t Like Me When I’m Angry
Here’s a good rule of thumb: Write all emails as if the distribution list included the entire planet because you never know when any given might come back to haunt you. If a certain executive at Standard Chartered had followed…