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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 […]

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), […]