File this under the category of all the ways that OFAC helps me sleep better at night. The Sarasota Yacht Club, which was probably founded by Che Guevara, cooked up a scheme to threaten U.S. national security by having a…
U.S. Senators Kirsten Gillibrand (D-NY) and Mark Kirk (R-IL), and U.S. Representatives Ted Deutch (D-FL) and Dan Burton (R-IN) today introduced the Iran Transparency and Accountability Act designed to strengthen U.S. unilateral sanctions against Iran. Although the text of the…
Trans Pacific National Bank recently agreed pay $12,500 penalty to the Office of Foreign Assets Control (“OFAC”) to settle charges that it had facilitated transactions by a foreign person where the transactions by the foreign person would be prohibited if…
If there is anything that qualifies as a true urban legend in the export areas, it’s the surprisingly widespread belief that shipments to overseas APO and FPO addresses aren’t exports. Of course, that’s no more true than the belief that…
Let’s say that you were an agency like the Bureau of Industry and Security (“BIS”) and you had a huge and complex list of sensitive items that needed a license for export. Now, unless your administrative goal was to collect…