More Screening Nightmares

I think more needs to be said about OFAC’s greater than 50 percent rule which was covered in yesterday’s post. As you recall, the rule in question says that if a blocked party owns more than 50 percent of another…

People Are from Earth; OFAC Is from Saturn

The latest technical amendments promulgated last Friday by the Office of Foreign Assets Control (“OFAC”) make me wonder where the people who write these rules come from. Mars, perhaps? No, further out. I’m guessing they come from Saturn because even…