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OFAC reports on licensing activities

Pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000, OFAC reports quarterly on license applications and approvals. The new one's out today. It has some nice charts and tables, showing license applications vs approvals by country and/or product, as well as a nice bar chart of the […]

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 rest of today’s OFAC designations…

I guess these weren't important enough to make Treasury's big press release. These are under the Iran and NPWMD sanctions programs: KHAKI, Parviz (a.k.a. “MARTIN”); DOB 26 Aug 1968; POB Tehran, Iran (individual) [NPWMD] [IFSR]. ALUMINAT (a.k.a. ALUMINAT PRODUCTION AND INDUSTRIAL COMPANY), Unit 38, 5th Floor, No. 9, Golfam Avenue, […]

Daddy takes over…

You know it's big news when the US Treasury Department issues the press release, not OFAC… Two big pieces of news on the Iran sanctions front. First, Sambouk Shipping FZC has been sanctioned as a front company for Dr. Dimitris Cambis, who was previously sanctioned for trying to evade the […]

Deep Questions: Why $1,075,000?

If you don't recognize that figure, it's the oft-quoted maximum civil monetary penalty per violation of the Foreign Narcotics Kingpin Designation Act (FNKDA or “Kingpin Act”). It's such a strange number – and yet, so explainable. The Federal Civil Penalties Inflation Adjustment Act of 1990, finally implemented in 2003, stipulates […]

Regulatory Spotlight: The first P in RPPR

P is for procedures… this is a lengthy section of the RPPR, so running this down in bullet form seems best… Licensing Specific licenses must be applied for by mail or courier, not electronically or by FAX. Applications to unblock funds transfers must use Form TD-F 90-22.54; other license applications […]