Sanctions Insights
2025
- Jan. 2025: US Sanctions UAE Trading Companies for Support of Sudanese Rebels
The United States remains focused on the UAE as a region of concern for sanctions enforcement.
2024
- Dec. 2024: Anti-WMD Proliferation Sanctions in Pakistan
The US State Department announced sanctions against three Pakistani companies and a government-owned entity. This action serves as a reminder that sanctions determinations are not limited to OFAC. - Dec. 2024: Musical instrument manufacturer’s OFAC settlement demonstrates value of self-reporting
A manufacturer of musical instruments based in California agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. - Dec. 2024: Lack of Sanctions Due Diligence in Foreign Acquisitions Leads to OFAC Penalty
The case illustrates the risk of failing to conduct adequate sanctions screening, as well as the advantages of self-reporting and cooperating with OFAC. - Oct. 2024: The “Engel List”: Corruption and Anti-Democracy Sanctions against Latin American Officials
While the list serves an important role in identifying the individuals responsible for corrupt practices in Central America, like many US “lists,” it presents significant challenges from a due process perspective. - July 2024: OFAC Sanctions Deserve To Be Challenged Post-Chevron
The unintended consequences of OFAC's expansion of the Specially Designated Nationals List.
2023
- Aug. 2023: OFAC Designation Prosecutions Are Constitutionally Suspect
In light of the severe consequences of running afoul of OFAC's directives, there has not been enough meaningful opportunity to challenge the scope and basis of OFAC's decision making. - Mar. 2023: US Sanctions Focus on the United Arab Emirates
The UAE is a “country of focus” for US investigators.
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The foregoing is for informational purposes only. It is not intended as legal advice and no attorney-client relationship is formed by the provision of this information.
Analysis of recent OFAC enforcement actions and other sanctions topics.