Blake Hulnick, former attorney-adviser in the Office of Foreign Assets Control’s chief counsel office, was named senior adviser to the Treasury Department’s general counsel, he announced on LinkedIn. Hulnick joined Treasury in 2023.
The U.S. Supreme Court's decision in Loper Bright v. Raimondo rejecting the Chevron principle of deferring to federal agencies' interpretations of ambiguous statutes doesn't call for the U.S. District Court for the District of Columbia to revisit a decision sustaining the sanctions designation of former Afghan government official Mir Rahman Rahmani and his son, Hafi Ajmal Rahmani, the U.S. said this week (Mir Rahman Rahmani v. Janet Yellen, D.D.C. # 24-00285).
David Horn was named assistant chief counsel for the Office of Foreign Assets Control, he announced on LinkedIn. Horn joined OFAC last year as an attorney adviser.
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Charlie Steele, former chief counsel for the Office of Foreign Assets Control, has joined London-based legal advisory firm Outer Temple Chambers as a professional associate, he announced on LinkedIn. Steele, who left OFAC in 2020, said his work at Outer Temple will focus on sanctions issues, the Committee on Foreign Investment in the U.S. and anti-money laundering. He said he will continue to operate the Law Office of Charles Steele, his Washington, D.C.-based solo practice.
Samuel Cutler, a former sanctions and export control lawyer with Miller & Chevalier, joined the Office of Foreign Assets Control as an enforcement officer, he announced last week on LinkedIn. Cutler said he began the new role this month.
The U.S. Supreme Court's recent decision upending the Chevron principle of deferring to federal agencies' interpretations of ambiguous statutes requires a more demanding review of the Office of Foreign Assets Control's use of the Global Magnitsky Act and International Emergency Economic Powers Act, sanctioned Mir Rahman Rahmani and his son, Hafi Ajmal Rahmani, argued (Mir Rahman Rahmani v. Janet Yellen, D.D.C. # 24-00285).
The Office of Foreign Assets Control urged a federal court late last month to dismiss the sole remaining claim in a lawsuit challenging the agency’s sanctioning of two former Afghan government officials for corruption.
Congress, federal agencies and state bar associations should work together on new regulations to ensure U.S. lawyers aren't enabling Russia-related sanctions evasion, Stanford Law School lecturer Erik Jensen and a host of law students recommended in a recent report.
A recent U.K. Supreme Court ruling could have implications for how certain sanctions-related payment issues are treated under force majeure clauses in contracts.