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Article

Ferrari & Associates, P.C. | USA, Venezuela | 15 Feb 2020

Conviasa: Is OFAC Closing the Cabin Door?

Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) identified Consorcio Venezuelano de Industrias

Article

Ferrari & Associates, P.C. | USA, South Sudan | 16 Dec 2019

South Sudan Sanctionable

It has been a while since we have posted, but we’re back by popular demand (actually, just one person’s polite request), and will try to begin

Article

Ferrari & Associates, P.C. | USA | 10 Jul 2019

Observe and Report: OFAC Issues Reminder on Annual Blocked Property Reports

The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has been busy over the past few weeks. First, a couple of

Article

Ferrari & Associates, P.C. | USA, Iran | 3 Jun 2019

Common Problem, Uncommon Consequence: The State Street Bank and Trust OFAC Enforcement Matter

Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the issuance of a Finding of Violation

Article

Ferrari & Associates, P.C. | USA | 5 May 2019

Framed: OFAC Sets Out Expectations for Compliance with U.S. Sanctions

Today, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published “A Framework for OFAC Compliance

Article

Ferrari & Associates, P.C. | USA | 18 Apr 2019

The Evolution of OFAC General Licenses for Legal Services

The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has discretion to both specifically license particular

Article

Ferrari & Associates, P.C. | USA | 17 Mar 2019

Three Tips for Filing an OFAC License Application to Unblock Funds

Every day, funds transfers are blocked by U.S. financial institutions and others due a belief that the blocking is necessary for compliance with U.S

Article

Ferrari & Associates, P.C. | USA | 23 Jan 2019

Fulmen Company v. OFAC: It Looks Like Everyone’s Going to Lose

As I have noted over the past year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has increasingly recently

Article

Ferrari & Associates, P.C. | USA | 2 Dec 2018

Shock Gen: The Dangers of the OFAC Voluntary Self-Disclosure

Last week, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Société Générale S.A

Article

Ferrari & Associates, P.C. | USA | 28 Aug 2017

Is OFAC’s Application of Its Iran Export Ban Reasonable? The Case of COSL Singapore Ltd.

On August 24, 2017, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement agreement with COSL

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