Free Food and Drink
If you are attending BIS Update 2015 and would like to get together for some free food and drink, please drop me an email at [email protected]. I have some invitations for a reception being held at Bryan Cave on the…
Keeping A List, Not Checking It Twice
BMO Harris Bank on Wednesday escaped an OFAC fine, even though it admitted to having processed six funds transfers totaling $67,357 representing payment by a customer of sums to an Iranian entity from which the customer had purchased Persian rugs.…
And The Jackpot Winner Is … New York!
Crédit Agricole just agreed to pay $787.3 million to settle charges that it violated the U.S. sanctions on Iran and other countries by stripping references to those countries in communications sent to U.S. banks to process dollar-based transactions. And to…
Beijing’s Review of U.S. Software Risks Export Woes for Those Who Allow It
An article that appeared last Friday in the Wall Street Journal suggests that at least one U.S. company is providing the Chinese government with access to proprietary U.S. source code as a condition for access to the Chinese market. What…
Federal Court Gives OFAC Carte Blanche to Seize Funds
A federal court recently upheld, in OKKO Business v. Lew, a decision by the Office of Foreign Assets Control (“OFAC”) to refuse to unblock funds sent by a Ukrainian company as an auction deposit for an auction conducted by a…