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  • Iran Sanctions, OFAC

OFAC Radically Expands Its Extraterritorial Jurisdiction with B Whale Ruling

The recent decision by the Office of Foreign Assets Control (“OFAC”) to issue a finding of violation, but no fine, against B Whale, a member of the Taiwanese TMT Shipping Group represents a new high (or low, depending on your…

  • Clif Burns
  • February 9, 2017
  • 2 Comments
  • Economic Sanctions, Iran Sanctions, OFAC

Sometimes Mistaken Identity Is Not A Laughing Matter

Last week, on the heels of Iran’s ballistic missile test, the Office of Foreign Assets Control (“OFAC”) announced new sanctions on Iran. These sanctions appear to have been in the works for some time judging by wealth of detail in the…

  • Clif Burns
  • February 7, 2017
  • Cyber Sanctions, OFAC

OFAC Answers Call To Fix Unintended Result of FSB Designation

In an earlier post, I pointed out an unintended consequence of the designation of the Vladimir Putin’s spy masters, the FSB, by the Office of Foreign Assets Control to punish the FSB for meddling in the last election. The problem…

  • Clif Burns
  • February 2, 2017
  • 1 Comment
  • Cuba Sanctions, Economic Sanctions, Foreign Countermeasures, OFAC

OFAC Fines Canadian Bank for Complying with Canadian Law

The Office of Foreign Assets Control (“OFAC”) recently whacked “Toronto-Dominion Bank â€¦ a financial institution headquartered in Toronto, Canada,” with a $516,105 fine for various sanctions violations including — get this — maintaining bank accounts for 62 Cubans in Canada.  Yes, OFAC…

  • Clif Burns
  • January 31, 2017
  • BIS, Encryption, OFAC, Russia Sanctions, Sanctions

OFAC Designation of Putin’s Spy Agency May Trip Up U.S. Exports

The recent OFAC sanctions on Russia’s FSB né KGB, which is the Kremlin’s spy agency, may have unintended consequences. According to this article on the Russian website by my friend Иван Ткачёв (Ivan Tkachev) the FSB, besides doing typical spy…

  • Clif Burns
  • January 24, 2017
  • 2 Comments
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