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Even non-profits can get fined…

The American Steamship Owners Mutual Protection and Indemnity Association, Inc. (the “American Club”) just got fined $348,000 for 55 non-egregious violations of the Cuban, Iranian and Sudanese sanctions programs that they did not voluntarily self-disclose. The transactions were maritime Protection and Indemnity (P&I) insurance claims, Letters of Undertaking (LOU – […]

The OFAC Book of Why: Cuba sanctions (Part 3)

Disclaimer: The information in this post comes from the documents on OFAC’s website and may not reflect current program details. The sanctions flyer for this program is dated January 24, 2012. Now, for the nitty-gritty – if the previous 2 posts weren’t gritty enough… First, transactions involving property of Cuba […]

The OFAC Book of Why: Cuba sanctions (Part 2)

Disclaimer: The information in this post comes from the documents on OFAC’s website and may not reflect current program details. The sanctions flyer for this program is dated January 24, 2012. Very little of Cuban origin can be exported from Cuba or brought into the US. “Informational materials,” which include […]

Evil Thought of the Day: March 22, 2013

What’s to prevent a country with blocked cargo vessels with changing the IMO number? If you changed the name (which Iran did with the IRISL vessels), changed the flagging (Iran has even changed the flagging without actually working with the country in question) and changed the IMO number (I assume […]