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  • Cuba Sanctions, OFAC

Just What Part of “Executory” Don’t You Understand?

A lawyer at another DC firm is having a conniption fit over the part of the new Cuba regulations that authorizes U.S. persons to enter into executory contracts in Cuba that are contingent upon OFAC approval. He apparently thinks that…

  • Clif Burns
  • October 24, 2016
  • 1 Comment
  • Criminal Penalties, Iran Sanctions, OFAC

Court Holds US Can Jail Anyone Anywhere for Dollar Based Transactions

ABOVE: Reza Zarrab I often joke about the number of foreigners who arrive in the United States with their families hoping to see Mickey Mouse but who wind up seeing Elliot Ness and a jail cell instead. Controversial Turkish businessman…

  • Clif Burns
  • October 21, 2016
  • 1 Comment
  • BIS, Cuba Sanctions, OFAC

North Pole Praises Today’s OFAC Actions

The following just arrived in my email: FOR IMMEDIATE RELEASE MEDIA CONTACT: Elf E. McElfface, [email protected] or (951) 262-3062 Santa’s Village, North Pole – Santa Claus today, on behalf of himself, Mrs. Claus and the 40,000 elfployees of the Santa…

  • Clif Burns
  • October 14, 2016
  • 3 Comments
  • BIS, Criminal Penalties, DDTC, OFAC, Voluntary Disclosures

DOJ to Exporters: Confession Is Good for the Soul

Apparently the National Security Division at DOJ had a bunch of interns this summer with nothing to do, because this is the only conceivable explanation for the mostly risible “Guidance Regarding Voluntary Disclosures” which the NSD released on October 2.…

  • Clif Burns
  • October 12, 2016
  • 1 Comment
  • Burma Sanctions, OFAC

Burma Sanctions Die and Dead Man Gets a Reprieve

On October 7, 2016, President Obama issued an executive order finding that the situation that led to national emergency declared in Executive Order 13047, and which led to the imposition of sanctions on Burma, had terminated. As a result of…

  • Clif Burns
  • October 10, 2016
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