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D.C. Circuit Affirms OFAC’s Broad Discretion to Deny De-Listing Requests, but Expect Regulatory Response | Holland & Hart's Trade Sanctions Blog
http://www.tradesanctions.com/d-c-circuit-affirms-ofacs-broad-discretion-to-deny-de-listing-requests-but-expect-regulatory-response
Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. July 15, 2015. DC Circuit Affirms OFAC’s Broad Discretion to Deny De-Listing Requests, but Expect Regulatory Response. Last Friday, the U.S. Court of Appeals for the D.C. Circuit issued a decision in Zevallos v. Obama et al. Before the D.C. Circuit, Mr. Zevallos reiterated his challenge to OFAC’s reliance on media reports but also argued that the appellate court should review OFAC’s denial of his request de. V Obama et al.
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OFAC Penalty for Iran Sanctions Violations Raises Questions Regarding Egregiousness Determination | Holland & Hart's Trade Sanctions Blog
http://www.tradesanctions.com/ofac-penalty-for-iran-sanctions-violations-raises-questions-regarding-egregiousness-determination
Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. June 22, 2015. OFAC Penalty for Iran Sanctions Violations Raises Questions Regarding Egregiousness Determination. Last Friday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with John Bean Technology Corporation (JBT). Of apparent violations of sanctions imposed on the Islamic Republic of Iran Shipping Lines (IRISL). OFAC designated IRISL. This entry was posted in Iran.
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OFAC Fires Warning Shots | Holland & Hart's Trade Sanctions Blog
http://www.tradesanctions.com/ofac-fires-warning-shots
Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. August 5, 2015. OFAC Fires Warning Shots. OFAC released a Crimea Sanctions Advisory. OFAC’s previous advisories regarding sanctions evasion by the Islamic Republic of Iran Shipping Lines (IRISL). And Exchange Houses and Trading Companies. Iran Sanctions Civil Penalty. On July 29, OFAC assessed a relatively minor civil penalty of $82,260 against Blue Robin, Inc. We will continue to monitor OFAC guidance and advisories, as well...
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July | 2015 | Holland & Hart's Trade Sanctions Blog
http://www.tradesanctions.com/2015/07
Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. Monthly Archives: July 2015. July 27, 2015. Week in Review and Look Ahead. Last week also signaled a recent significant shift at FinCEN that will result in a drastic increase in its 311 actions. Businesses that rely on foreign banks especially those in Central and South America and the Middle East should be on notice that they are now much more likely to be cut off from the U.S. financial system. Continue reading →. DC Circui...
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Week in Review and Look Ahead | Holland & Hart's Trade Sanctions Blog
http://www.tradesanctions.com/week-in-review-and-look-ahead
Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. July 27, 2015. Week in Review and Look Ahead. Last week also signaled a recent significant shift at FinCEN that will result in a drastic increase in its 311 actions. Businesses that rely on foreign banks especially those in Central and South America and the Middle East should be on notice that they are now much more likely to be cut off from the U.S. financial system. The Office of Foreign Assets Control. This final rule foll...
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Iran | Holland & Hart's Trade Sanctions Blog
http://www.tradesanctions.com/category/iran
Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. May 4, 2016. Recent Court Decision Provides Insight Into Enforcement of OFAC Sanctions. On March 7, the District Court for the District of Columbia issued a Memorandum Opinion granting the government’s Motion for Summary Judgment in the matter of Epsilon Electronics, Inc. v. United States Department of the Treasury, Office of Foreign Assets Control, et al. Continue reading →. This entry was posted in Iran. May 4, 2016. In 201...
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Ukraine | Holland & Hart's Trade Sanctions Blog
http://www.tradesanctions.com/category/ukraine
Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. December 22, 2015. OFAC Actions Against Russia Increase Certainty for Compliance Programs. In the press release. Continue reading →. This entry was posted in OFAC. December 22, 2015. May 22, 2015. Ukraine-Related General License No. 9. By Jeremy P. Paner. Today, OFAC issued Ukraine-related General License No. 9. This entry was posted in OFAC. May 22, 2015. Enter your email address:. No Sanctions Compliance Program?
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August | 2015 | Holland & Hart's Trade Sanctions Blog
http://www.tradesanctions.com/2015/08
Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. Monthly Archives: August 2015. August 31, 2015. Cyber Designations: What to Expect and How to Respond. Indicate that the U.S. Treasury Department is preparing designations under its malicious cyber-enabled activities authority. Prior to these reports, which cite anonymous administration sources, there were clear signs that this sanctions authority would probably remain dormant. Empty Executive Order, Without Regulations.
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May | 2015 | Holland & Hart's Trade Sanctions Blog
http://www.tradesanctions.com/2015/05
Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. Monthly Archives: May 2015. May 22, 2015. Ukraine-Related General License No. 9. By Jeremy P. Paner. Today, OFAC issued Ukraine-related General License No. 9. Exportation of Certain Services and Software Incident to Internet-Based Communication Authorized) and accompanying FAQ 454. This entry was posted in OFAC. May 22, 2015. May 22, 2015. OFAC Targets Mexican and Colombian Cocaine Trafficking Networks. Continue reading →.
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Uncategorized | Holland & Hart's Trade Sanctions Blog
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Holland and Hart's Trade Sanctions Blog. Holland & Hart’s Export Controls Blog. June 14, 2016. US Treasury’s 311 Action Against North Korea Intensifies Pressure on China. The US. Department of the Treasury recently announced. A finding that North Korea is a jurisdiction of primary money laundering concern pursuant to its Section 311 authority, codified at 31 U.S.C. 5318A. Treasury’s Financial Crimes Enforcement Network (FinCEN) also released a notice of proposed rulemaking. June 14, 2016. Individuals who...