I Think This Is What You Call Cold Comfort

Last week, the Office of Foreign Assets Control (“OFAC”) issued an interpretative guidance on section 560.545 of the Iranian Transactions Regulations which permits exports from the United States to Iran of services incidental to the exchange of personal information over…

The eCFR Strikes Back

So, this afternoon, I was on the phone with a client who had a question about the Cuba sanctions enforced by the Office of Foreign Assets Control (“OFAC”). As I often do in these situations, I went to the OFAC…