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  • OFAC, SDN List

OFAC Releases Frequently Misleading Answers to FAQs on SDN Delisting

The Office of Foreign Assets Control today issued FAQs on the process whereby OFAC removes people from its List of Specially Designated Nationals and Blocked Persons. Sadly, the answers to those FAQs don’t really tell the whole story.  You might…

  • Clif Burns
  • April 20, 2017
  • Criminal Penalties, OFAC, SDN List

Indictment of SDN Ignores OFAC’s 50 Percent Rule

ABOVE: Kassim Tajideen Prosecutors love to add cute little nicknames to indictments.   In their view, United States v. John Jones aka Vicious Johnny the Kneecapper sounds much, much better than plain old vanilla United States v. John Jones.  So,…

  • Clif Burns
  • April 18, 2017
  • DDTC, Export Reform

Un Pour Deux, Deux Pour Un! (An ECR Swashbuckler)

ABOVE: Brian J. Nilsson Many readers were likely wondering what impact the Trump Administration’s new one-for-two executive order would have on export control reform. As you probably know, that is the order that says for every new rule adopted by…

  • Clif Burns
  • April 11, 2017
  • 1 Comment
  • North Korea Sanctions, OFAC

Wilkommen im Hotel Norkschwein

One of the problem with the Nork sanctions passed by the U.N. is that they rely on member states for their enforcement and not all member states are, well, super excited about sanctioning the Norks. We’re looking at you, China.…

  • Clif Burns
  • April 6, 2017
  • Civil Penalties, OFAC, SDN List

American University in Beirut Dinged by DOJ for SDN Listing in Directory Database

The American University in Beirut (the “AUB”) recently agreed to pay $700,000 to settle claims in a civil suit under the False Claims Act brought by the United States. One of the violations alleged was that the AUB, while receiving funds…

  • Clif Burns
  • April 5, 2017
  • 1 Comment
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