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CLANCY v. OFFICE OF FOREIGN ASSETS CONTROL

No. 07-2254.

559 F.3d 595 (2009)

Ryan CLANCY, Plaintiff-Appellant, v. OFFICE OF FOREIGN ASSETS CONTROL OF the UNITED STATES DEPARTMENT OF the TREASURY, Timothy F. Geithner, Secretary, United States Department of Treasury, in his official capacity, Adam J. Szubin, Director, Office of Foreign Assets Control, in his official capacity, and Eric H. Holder, Jr., Attorney General, United States Department of Justice, in his official capacity, Defendants-Appellees.

United States Court of Appeals, Seventh Circuit.

Decided March 11, 2009.

Attorney(s) appearing for the Case

James A. Friedman (argued), Godfrey & Kahn, Madison, WI, for Plaintiff-Appellant.

Douglas Letter (argued), Department of Justice Civil Division, Appellate Section, Washington, DC, for Defendants-Appellees.

Before BAUER, KANNE, and WILLIAMS, Circuit Judges.

WILLIAMS, Circuit Judge.

Having declared a national emergency to deal with the threat of Iraq in 1990, President George H.W. Bush imposed economic sanctions prohibiting unauthorized travel to Iraq and authorized the Treasury Department's Office of Foreign Assets Control ("OFAC") to promulgate regulations in accordance with those executive orders. In 2003, Clancy traveled to Iraq in violation of those regulations and was fined $8,000 by OFAC. Clancy challenged OFAC...

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