• On November 28, 2018, OFAC designated two Iran-based individuals who helped exchange cryptocurrency (bitcoin) into fiat currency on behalf of alleged ransomware perpetrators who targeted U.S. businesses and municipal...more
1/11/2019
/ Bitcoin ,
Blocked Person ,
Corporate Counsel ,
Crypto Exchanges ,
Cryptocurrency ,
Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Digital Currency ,
Digital Wallets ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
SDN List ,
U.S. Treasury
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
In this podcast, Akin Gump’s international trade partners Mahmoud Baki “Mac” Fadlallah (Dubai), Jasper Helder (London) and Wynn Segall (Washington, D.C.) discuss three pivotal regions related to U.S. sanctions under the...more
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more
8/17/2018
/ Blocking Statutes ,
Economic Sanctions ,
EU ,
Executive Orders ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Winding Down ,
Withdrawal
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
On January 12, 2018, the U.S. administration took three actions relating to Iran -
• First, President Trump waived again the application of certain nuclear sanctions while making clear that the United States will refuse to...more
• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...more
11/2/2017
/ Anti-Terrorism Financing ,
Decertify ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Nuclear Agreement Review Act of 2015 (INARA) ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Legislative Amendments ,
Members of Congress ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
SDN List ,
Sunset Provisions ,
Trump Administration ,
U.S. Treasury
• This enforcement action highlights the heightened sanctions compliance and enforcement risk that companies face when engaging third-party consultants to perform due diligence on counterparties. U.S. persons must make clear...more
8/28/2017
/ Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
General Licenses ,
Imports ,
IPSA ,
Iran ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Settlement
On July 27, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the civil settlement with CSE TransTel Pte. Ltd. (“TransTel”) and CSE Global Limited (“CSE Global”) in the amount of...more
8/12/2017
/ Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
Iran ,
Iran Sanctions ,
Jurisdiction ,
Non-US Entities ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Sanction Violations ,
SDN List ,
Section 203 ,
Settlement
On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. Law. No. 115-44, H.R. 3364) (the “Act”), which significantly expands economic sanctions against...more
8/9/2017
/ Anti-Corruption ,
Anti-Terrorism Financing ,
Arms Embargo ,
Congressional Override ,
Cyber Sanctions ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Oil & Gas ,
Pipelines ,
Privatization ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Syria ,
Trade Restrictions ,
Trump Administration
Key Points -
- The U.S. Department of the Treasury’s Office of Foreign Assets Control has added 25 new entities and individuals to its Specially Designated Nationals List, including some located in China, Lebanon,...more
On December 23, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Final Rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR) to expand the...more
On October 7, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published new guidance clarifying (a) circumstances under which non-U.S. financial institutions (FFIs) may engage in U.S. dollar...more
On July 29, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued a new General License J (GL-J). GL-J authorizes the reexportation of certain civil aircraft on temporary sojourn to Iran,...more
On January 16, 2016, the International Atomic Energy Agency (IAEA) verified, and U.S. Secretary of State John Kerry confirmed, that Iran had implemented its key nuclear-related measures described in the Joint Comprehensive...more
If you read one thing...
- There are far greater opportunities for U.S. companies with respect to Iran, particularly through foreign subsidiaries and in the commercial aviation sector, however, U.S. persons and...more
On October 18, 2015, the day on which the Joint Comprehensive Plan of Action (“JCPOA”) became effective (“Adoption Day”), the U.S. Department of State (“State Department”) issued contingent waivers of certain extraterritorial...more
10/21/2015
/ Banking Sector ,
Energy Sector ,
Export Controls ,
Exports ,
IAEA ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
US Department of State ,
Waivers
On July 14, 2015, Iran and the P5+1 countries (China, France, Germany, Russia, the United Kingdom and the United States), with the High Representative of the European Union for Foreign Affairs and Security Policy, finalized...more
7/16/2015
/ Aircraft Equipment ,
Airlines ,
EU ,
Foreign Trade Regulations ,
Imports ,
Inspections ,
International Atomic Energy Agency ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Member State ,
Multinationals ,
P5+1 Nations ,
SDN List ,
UN Security Council ,
United Nations
As nuclear negotiations in Vienna reach the targeted June 30, 2015, deadline for an agreement, the P5+1, EU and Iran agreed today to extend the limited and temporary sanctions relief to Iran through July 7, 2015. The...more
Thursday, negotiators from the United States, Iran and other world powers announced they have agreed on a framework for a Joint Comprehensive Plan of Action regarding Iran’s nuclear program to be finalized by June 30, 2015....more
Introduction and Summary -
On January 20, 2014, the departments of State and the Treasury announced details of the United States’ plan to suspend certain sanctions against Iran pursuant to the November 24, 2013 Joint...more