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  • Cuba Sanctions, OFAC

Banks Caught Between Scylla (OFAC) and Charybdis (Customer Wrath)

By now, we’ve all seen these stories. A slightly dimwitted, possibly drunk, prankster writes “I ❤ ISIS” in the memo line of a check or in the description field of an online payment service and then is shocked, shocked to…

  • Clif Burns
  • May 4, 2016
  • 1 Comment
  • BIS, Cuba Sanctions, OFAC

Two Heads Are Not Always Better Than One

The Office of Foreign Assets Control (“OFAC”) last week updated its Cuba FAQs with this perplexing little blurb that can only charitably actually be called an “answer” or the “A” in FAQ. 68. May a person subject to U.S. jurisdiction…

  • Clif Burns
  • April 28, 2016
  • 1 Comment
  • BIS, China, Criminal Penalties

Woman Indicted for Failure to File Electronic Export Information Forms

ABOVE: Harbin Engineering University Amin Yu bought things for Harbin Engineering University (“HEU”) in China — all EAR99 items, none of which required an export license. She listed an incorrect value for the items on documents that she gave to…

  • Clif Burns
  • April 25, 2016
  • 1 Comment
  • Anti-Boycott, BIS, Cuba Sanctions

No Cuban-Americans Allowed

On Tuesday of this week two Cuban-born residents of Florida filed a lawsuit against Carnival cruise lines and its subsidiary Fathom Travel for violating their civil rights by refusing to book passage for them on a cruise ship from Miami…

  • Clif Burns
  • April 14, 2016
  • 1 Comment
  • Criminal Penalties, Iran Sanctions, OFAC

Texas Millionaire’s Release in Iran Prisoner Swap Remains a Mystery

An excellent and detailed article in the Houston Press, an alternative weekly news magazine and website, ponders the reason that a Texas millionaire, Bahram Mechanic, was on Iran’s prisoner swap list and received, as part of the prisoner swap negotiated…

  • Clif Burns
  • April 12, 2016
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