2013 was a banner year for the U.S. sanctions program against Iran.  For the first time in recent history, not all of the big Iran news involved new restrictions and prohibitions.  True, there were plenty of those, especially during the beginning of the year as the U.S. government implemented legislation passed in 2012.  But the most noteworthy Iran development in 2013 – a tentative nuclear agreement between Iran and six world powers – proved that diplomacy may be an alternative to ever-tightening sanctions.  With that single development came the possibility, remote though it may still be, that Iran’s economy could someday reopen to international business.

Here, we look back at important developments of 2013 and contemplate what 2014 might hold for U.S. sanctions on Iran.


Continue Reading Iran Sanctions: 2013 and Beyond

On February 6, 2013, the Office of Foreign Assets Control (OFAC) published two guidance documents related to the Iranian sanctions regulations and licenses.  The first is Guidance on Humanitarian Assistance and Related Exports to the Iranian People.  While the guidance is simply an overview of previously-issued exceptions, the publication is nonetheless an indication of Washington’s efforts to encourage those projects and transactions that benefit the Iranian people directly.


Continue Reading ALERT: Clarifications of the Iranian Sanctions Regulations

By: Thad McBride and Cheryl Palmeri

The start of the new year is the perfect time to reflect on the international trade enforcement actions of the past year and to predict what they might mean for the year ahead.  This exercise is made exponentially easier by the “Summary of Major U.S. Export Enforcement, Economic Espionage, Trade Secret, and Embargo-Related Criminal Cases” (the “Enforcement Summary”) which recently was updated through December 6, 2012.  The Enforcement Summary suggests a number of important trends in export enforcement and embargo-related cases.

Continue Reading Iran, China, and Prison: A Recap of 2012’s Major Export Enforcement and Embargo-Related Criminal Cases

By: Reid Whitten

Although the traditional Burmese New Year actually falls in April, many U.S. companies are turning a new page on their calendars with thoughts of the new opportunities that await in the rapidly-opening southeast Asian nation.  This past year, this blog tracked the reduction of restrictions imposed on Burma by the United States.  To round out 2012 and kick off 2013, we present a few New Year’s resolutions that U.S. companies may consider as they approach a country offering great potential growth but pitted with potential legal challenges.
Continue Reading Foreign Investment in Burma: Resolutions for Business in a Very New Year

By: Neil Ray and Curtis Dombek

The risks of trading with Iran have never been greater. U.S. and European authorities, in particular, are scrutinizing exports to Iran more closely than ever under both sanctions and export control laws. On January 23, 2012, the Council of the European Union (EU) adopted an unprecedented package of sanctions complementing the existing EU sanctions against Iran.  The new sanctions reflect the EU’s deepening concern over the nature of Iran’s nuclear program.  The new measures include:
Continue Reading EU’s New Sanctions Target Iran’s Oil Industry

By: Curtis Dombek and Dan Brooks

On January 18, 2012, the European Union adopted Council Regulation No. 36/2012 (“Regulation 36/2012”), which imposes new restrictions on companies doing business in Syria.  Regulation 36/2012, which repeals and replaces previous measures adopted by the EU in May 2011, has particular implications for companies operating in the oil and gas, energy, and telecommunications sectors.

Continue Reading EU Imposes New Economic Sanctions on Syria