JM 4-6.380
Area 8 involves the defense of a broad range of constitutional and Administrative Procedure Act challenges to programmatic actions of the Departments of Treasury and Commerce that fall primarily within the ambit of foreign and domestic commerce. Much of our work in this area involves consultation with the Treasury and State Departments (including the Office of Foreign Assets Control) on economic sanctions issues and defense of lawsuits challenging various aspects of the sanctions, including designations of persons and freezing of their assets pursuant to the Trading with the Enemy Act and the International Emergency Economic Powers Act, actions denying licenses to access blocked property, as well as challenges to civil penalties imposed for sanctions violations.
This area also includes matters involving Bureau of the Census; Export Administration Act; National Weather Service; and miscellaneous Commerce and Treasury litigation or other matters.
[updated April 2018]