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
On May 23, 2025, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 25 (“GL 25”), effectively lifting U.S. sanctions on Syria. This move follows President Trump’s announcement on...more
In another step to deprive a sanctioned country of revenues from petroleum sales, the U.S. government recently sanctioned more than 30 entities and vessels located around the world for their role in brokering the sale and...more
As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more
Following President Trump’s announcement of his administration’s intention to ratchet up sanctions against Iran, OFAC announced Thursday that it is designating a number of Chinese, Indian, and UAE entities as Specially...more
President Trump issued a new Executive Order renewing a commitment to imposing “maximum pressure” on the Iranian government to “end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist...more
Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more
In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more
Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...more
Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. ...more
On February 23, building mainly upon the broad authority of Executive Order 14024 (“EO 14024”)[1] issued by President Joe Biden in 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more
Emigrant Bank (“Emigrant”), a U.S.-based financial institution that bills itself as the oldest bank in New York City, is the latest sanctions violator to be swept up in OFAC’s ongoing enforcement push. On September 21, OFAC...more
The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...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
In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023, aimed specifically at reminding industry of their...more
In this post, we describe the economic sanctions imposed by Canada since our March 28, 2023 update, including additional designations of Russian, Belarusian, Iranian and Haitian persons under existing sanctions regimes and a...more
Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million. Murad was acquired by Unilever United...more
The U.S Treasury Department’s Office of Foreign Assets Control (OFAC) recently announced settlements with a California-based cosmetics company and a former senior company executive to resolve potential civil liability...more
On April 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 14078, against four senior officials of Iran’s Islamic Revolutionary Guard Corps...more
On February 27, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Iran Final Rule”) imposing new export control measures against Iran caused by to its support of Russian...more
In this post, we describe the economic sanctions imposed by Canada since our November 5, 2022 update, as well as Russian asset freezing order and a judicial decision in the sanctions law area. We expect more sanctions and...more
On March 21, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions in coordination with the FBI against four entities and three individuals in Iran and Turkey accused of supporting Iran’s...more