The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
EMBARGOED! Episode 43: Russia and Iran and China, Oh My!
Washington Post Journalist Jason Rezaian on His Iranian Imprisonment
Nota Bene Episode 64: U.S. Check In: Prescription Drugs, USMCA, Privacy, Impeachment and Iran with Elizabeth Frazee and Jonathan Meyer
As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more
Broad Tariff Increases Could Reshape Global Trade: The aggressive use of tariffs could create significant trade disruptions for businesses dependent on global supply chains, and pair novel use of authorities with existing...more
Since Israel killed Iran Revolutionary Guard Commander General Mohammed Reza Zahedi and six others in Damascus, Syria on April 2, Iran has sworn that it will retaliate harshly against Israel. Israeli soldiers have had their...more
On February 24, the two-year anniversary of Russia’s invasion of Ukraine, the Biden administration issued hundreds of new Russia-related export controls and sanctions. The Office of Foreign Assets Control (OFAC) and the...more
The pessimist complains about the wind; the optimist expects it to change; the realist adjusts the sails. – William Arthur Ward The U.S. maritime industry is much like a great ship: It is subject to unforeseen forces, and it...more
When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. ...more
Construction Specialties, Inc. (“CSI”), a U.S. company specializing in the sale of building materials, agreed to pay $660,594 to settle its liability for three violations of OFAC’s sanctions on Iran. CSI’s illegal conduct...more
After months of negotiations, Congress revealed the compromise version of the National Defense Authorization Act for Fiscal Year 2023 (NDAA) on December 6, 2022. The bill, viewed as a “must-pass” piece of legislation because...more
Cryptocurrency companies are in trouble. Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting...more
Introduction - On October 3, 2022, the Honourable Melanie Joly, Canada’s Minister of Foreign Affairs, announced that Canada was imposing sanctions on 25 Iranian officials and 9 Iranian entities/organizations that are...more
2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more
It seems almost every day there are reports of new developments under the U.S. sanctions laws. Yet many U.S. companies do not understand the significance of these laws....more
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
Indictment Alleges that Bank and its Officers Used Front Companies to Evade Prohibitions on Iran’s Access to the U.S. Financial System - The U.S. Attorney for the Southern District of New York has charged Turkish state-owned...more
On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more
Stepping outside of SWIFT - Since its inception more than a decade ago, cryptocurrency has been viewed as a way to supplant traditional global methods of exchanging money. Today, as virtual currencies proliferate,...more
• 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
• On October 11, 2018, FinCEN released an advisory to help U.S. financial institutions better detect potentially illicit transactions related to Iran. • The advisory describes how Iran attempts to access the international...more
U.S. embargoes and economic sanctions on countries such as Iran, Russia and Cuba were discussed at length by both candidates during the 2016 Presidential campaign, and President-Elect Trump has stated that he intended to...more
Election Day brought an end to a long period of uncertainty that caused market fluctuations and delayed business planning decisions. As we navigate the post-election landscape, many questions remain regarding the potential...more
Over the past year, the big news for companies doing or considering business in Iran has been the scaling back of U.S. and EU economic sanctions. Many global businesses are now permitted to operate in this once prohibited...more