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The OFAC Book of Why: Somalia sanctions

The Somalia sanctions are another targeted sanctions program, as most are these days. Rather than rephrasing, let's just look at the sanctions flyer, slightly edited for length: On April 12, 2010, President Obama signed Executive Order 13536 (the “E.O.”) declaring a national emergency todeal with the unusual and extraordinary threat […]

Why IFCA? Sec. 1243 tells all…

This is the first of many posts on IFCA sanctions – we're going to answer the basic question: why is the US doing this? This is the Sense of Congress section which explains why sanctions are being imposed and what we want to do in terms of sanctions: SEC. 1243. […]

Undersecretary Cohen Testifies about Iran Sanctions

David Cohen is Undersecretary of Terrorism and Financial Intelligence, and he recently testified before the Senate Committee on Banking, Housing and Urban Affairs. The topic: Iran Sanctions: Ensuring Robust Enforcement, and Assessing Next Steps. Some highlights – on CISADA: When I last appeared before the Committee, I described the Administration's […]

IFCA clarification

See what happens when a layman tries to read a lengthy law?   IFCA, the Iran Freedom and Counter-Proliferation Act, is, as previously reported, Subtitle D in the National Defense Authorization Act of 2013. But, there are many Subtitle Ds in the NDAA. Just so you know, IFCA is Subtitle […]