office of foreign assets control Archives | Customs & International Trade Law Blog

Vegas Woman Charged with Iran Sanctions Violations

A Las Vegas woman has been indicted by a federal grand jury for conspiracy to export goods from the United States to Iran, in violation of the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations. According to the indictment unsealed recently, Tina Chen, 47 — aka Ya When Chen, Wen Tina Chen, Tina Dunbar, and Tina Dubner — is the owner of Top One Zone, LLC, a company exporting electronic and computer components that Chen operates from her residence. As alleged, from about November 2015 to May 2019, Chen conspired with others to buy and export goods from companies in the United States, and then send those goods to individuals in Iran through companies in Hong Kong. Chen concealed the identities of the end users, and she did not have a license from OFAC. Chen is charged with one count of conspiracy to unlawfully export goods to Iran.

According to the allegations in the indictment, Chen engaged in numerous overt acts of conspiracy including:

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By Jennifer Diaz|2021-10-07T14:41:14-04:00July 23, 2021|EAR, EEI, Export, International Trade, IRAN, U.S. Department of Commerce (DOC), U.S. Office of Foreign Assets Control (OFAC)|Comments Off

Between a Rock and a Hard Place – Conflicting U.S. & EU Sanctions Policies Towards Iran

Background on U.S. Sanctions Programs

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) administers a number of different sanctions programs. The purpose of U.S. sanctions programs is to advance U.S. foreign policy objectives and protect national security. Currently, OFAC administers 35 sanctions programs. These sanctions programs vary widely – some are comprehensive while others are highly selective.

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By Jennifer Diaz|2021-10-07T14:44:56-04:00June 15, 2021|Export, International Trade, IRAN, Trade Policy, U.S. Office of Foreign Assets Control (OFAC)|1 Comment

OFAC Sanctions & Licensing

Background on U.S. Sanctions (as of May, 2021)

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) administers a number of different sanctions programs. The purpose of U.S. sanctions programs is to advance U.S. foreign policy objectives and protect national security. Currently, OFAC administers 35 sanctions programs. These sanctions programs vary widely – some are comprehensive while others are highly selective.

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By Jennifer Diaz|2022-07-07T12:38:48-04:00June 1, 2021|China, Cuba, Export, International Trade, IRAN, U.S. Office of Foreign Assets Control (OFAC)|1 Comment

Submitting a Voluntary Self-Disclosure to OFAC

Diaz Trade Law’s President, Jennifer Diaz, and Associate Attorney, Sharath Patil, are enthusiastic to announce Bloomberg Law published another one of our articles, “Submitting a Voluntary Self-Disclosure to OFAC”! Below is the article reproduced with permission for your reading pleasure. We’d love to hear your feedback!

You can read the article here (where you’ll have the ability to access all of the great hyperlinks). Please note you cannot click on the hyperlinks below.

We’d love to hear your feedback!

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By Jennifer Diaz|2021-07-23T16:46:12-04:00April 6, 2021|Best Practices, Enforcement, Export, International Trade, U.S. Office of Foreign Assets Control (OFAC)|Comments Off

OFAC Increases Civil Monetary Penalties

On March 19, 2018, the Office of Foreign Assets Control (OFAC) adjusted its maximum civil monetary penalties for inflation (per the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015). The rationale for this increase is to maintain and improve the effectiveness and deterrent effect of civil monetary penalties. Any increase applies to penalties assessed after the effective date regardless of whether the violation occurred prior to such date.

How much did civil monetary penalties increase? […]

By Jennifer Diaz|2021-11-04T15:31:43-04:00April 4, 2018|Export, U.S. Office of Foreign Assets Control (OFAC)|Comments Off

The Journal for Export Control Professionals

I am pleased to share with you a new periodical, "World Export Controls Review - the journal of export controls and compliance," published by Brightlaw Media Ltd., London, England. The first issue published in March 2011 is free. The April 2011 publication contains my article entitled "Responding to an Administrative Subpoena Issued by the Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury."

By Jennifer Diaz|2019-10-22T01:26:23-04:00April 29, 2011|Export, U.S. Office of Foreign Assets Control (OFAC)|Comments Off

Forbidden Places for Tourism and Trade

Please make plans to attend the Forbidden Places -- Tourism and Trade seminar on September 24, 2010. This seminar will take place at the J.W. Marriott Hotel, Miami, Florida. This half-day seminar will address a variety of recent regulations administered by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury. Topics to be addressed include travel to and trade with restricted countries, immigration aspects of tourism to sanctioned countries, and representing a client who is the subject of an investigation or penalty by the OFAC.

By Jennifer Diaz|2010-08-30T20:35:16-04:00August 30, 2010|Events, U.S. Office of Foreign Assets Control (OFAC)|3 Comments

Everything You Need to Know About Exporting

In the next few weeks, I am giving lectures and doing a webinar on the general topic of export compliance. In my legal practice over the past 20 years as a Customs and International Trade attorney, I am increasingly involved with clients on export compliance and penalty matters, especially with the BIS and OFAC. The laws and regulations have changed dramatically over the past few years, as has the name and number of Federal agencies enforcing them, plus the penalties for non-compliance are much higher now.

By Jennifer Diaz|2009-11-16T11:16:52-05:00November 16, 2009|Export, U.S. Bureau of Industry and Security (BIS), U.S. Office of Foreign Assets Control (OFAC)|Comments Off