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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 […]

Regulatory Spotlight: The first R of the RPPR

The Reporting, Procedures and Penalties Regulations (RPPR) is a queer duck (it's an expression – get used to it). It has three distinct, albeit loosely related sections: reporting and recordkeeping, general rules and procedures for changes made to sanctions regimes, and penalties under the Trading with the Enemy Act (TWEA), […]

The OFAC Book of Why: Liberian Sanctions

Acting under the authority of the International Emergency Economic Powers Act (IEEPA) and the section 5 of the United Nations Participation Act (UNPA), President George W. Bush issued Executive Order 13384 on July 22, 2004 to sanction the regime of former Liberian President Charles Taylor. The resulting Former Liberian Regime […]

May 2, 2013: OFAC removes 10 from Zimbabwe sanctions

The following have been removed from the Specially-Designated Nationals (SDN) list: MUDENGE, Isack Stan Gorerazvo, 31 St. Brelades Road, Borrowdale, Harare, Zimbabwe; DOB 17 Dec 1948; Passport AD000964 (Zimbabwe); Minister of Higher and Tertiary Education (individual) [ZIMBABWE]. CHINDORI-CHININGA, Edward; DOB 14 Mar 1955; Passport AN388694 (Zimbabwe); Member of Parliament for […]