About: Erich Ferrari

Recent Posts by Erich Ferrari

A Sanction For (Almost) Every Reason

I suppose the President has gotten tired of Congress getting all of the attention when it comes to imposing new sanctions on Iran. Earlier this week, he issued a new executive order implementing certain sanctions that were previously called for in the Iran Freedom and Counter Proliferation Act (IFCA) and adding some new sanctions of...
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Bad Sanctions: Who’s to Blame?

I was recently re-reading the Judicial Review Commission Report on Foreign Assets Control (“Report”), a 2000 report on the implementation of the Foreign Narcotics Kingpin Designation Act (“Kingpin Act”). A few key points from that Report got me thinking about the overall state of U.S. economic sanctions and where some of the more onerous provisions...
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OFAC Starts Off 2013 With An Enforcement Action

On the first business day of the new year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $191,700 settlement of sanctions violations with Ellman International, Inc. (“Ellman”) for apparent violations of the Iranian Transactions Regulations (“ITR”). Under it’s prior ownership and management Ellman exported products to Iran and...
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The Upward Spiral: A Timeline of HSBC’s Iran Sanctions Violations

Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), announced their second massive penalty of the week when it was made public that HSBC was remitting $375 million dollars to settle allegations that HSBC, through its U.S. subsidiary, HSBC USA (HBUS), violated OFAC sanctions targeting Iran, Burma, Sudan, Cuba, and...

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