How OFAC operates

OFAC's way of business:

OFAC experts say the agency keeps its rules vague, its people are notoriously slow, and extremely arrogant. The agency’s civil enforcement history is largely a black hole. With little or no accountability at all, OFAC people will step over all laws and go beyond their boundaries in order to evade allowing the people they designated their legal rights which are specified in the regulations. An easy example will be OFAC’s common denial of releasing payment for attorneys and legal services of designated persons. In the absence of lawyers, a designated person would not be able to fight OFAC, thus, OFAC is guaranteed to win.

The ABC of OFAC's Operation

OFAC does not initiate action, it is rather ordered to take action against targets that are usually identified by other departments and agencies, mostly the State Department.  Think of OFAC as a vicious dog of mad master, if the master hates you he will seek OFAC to bite you, this is as simple as it can be.

OFAC will move ONLY at the order of the president, that means an executive order is the starting point for their action. An executive order is pure politics usually used by the president to do something the laws and regulations would not permit.   The executive order is usually designed by somebody other than the president, most likely the State Department. However, it is issued by the president because he holds the power to do that.   The executive order is usually valid for one year; however, once issued it is likely to remain valid forever on the efforts of OFAC to renew it every year, because without executive orders, there will be no need for OFAC services. Only upon the issuance of an executive order, which is usually drafted and prepared by OFAC itself, OFAC goes to  work.

Because OFAC is not a law enforcement agency, it usually enlists the help of the FBI to scare and terrorize its targets. The FBI, Homeland Security, and ICE will usually be the entity to obtain search warrants and knock on targets' doors; OFAC NEEDS NO WARRANTS, thereafter, OFAC agents come and tell you "your life has been destroyed."  The use of other agencies allows OFAC and the other participants to play the "good-cop/bad-cop" game, where everyone blames the other, while the evidence gets lost between them, and the bureaucracy is multiplied; thus, the victim cannot get results. Terroristic Nazi-tactics, dishonorable, immoral, unconstitutional, and unjust but it works perfect for regimes in need for something like OFAC.

OFAC and the United Nations:

By the virtue of the United States domination over the United Nations and the UN Security Council, OFAC maintains a master-to-slave relation when it comes to the United Nations and its, so-called, Security Council.

Generally, OFAC uses the United Nations' Security Council in efforts to make its actions appear to be done on legal grounds drawn from a Security Council resolution, and which gets to be created by OFAC itself.  The way it works is by OFAC drafting a UN resolution against whomever they want to target, then having the United States government file and pass the resolutions in the UN, then OFAC uses that resolution to make its illegal action appear legal based on compliance with the UN Security Council resolution which they have created. This could be hard to believe, but it is the reality and OFAC's former employees have no problem bragging about it to market themselves by saying that “they were drafting the presidential executive orders and the United Nations Security Council resolutions.”  You can see an example at one of OFAC's lawyers website, the lawyer is Hal Eren and his website located at http://www.erenlaw.com/lawyers/heren.html available here in PDF.

Needless to say that reality and justice do not mean anything in OFAC operations. OFAC is founded to execute political agenda, not to serve a legal purpose. Legal issues, assessment of evidence, and the determination of whether a person is guilty or innocent in respect to allegation of a crime usually take place in a court of law as mandated by the Constitution of the United States.

OFAC Operation schematic

OFAC OPERATIONS DIAGRAM