On July 17, 2017, the U.S. State Department certified that Iran continues to meet the conditions of the Iran nuclear agreement known as the Joint Comprehensive Plan of Action, or JCPOA. As a result, for the next 90 days, the United States will maintain significant reductions in its sanctions against Iran as provided in the … Continue Reading
A President Trump will have authority to reinstate sanctions lifted by the Iran Nuclear Deal as well as revoke certain authorizations provided for business with Iran. Several economic and geopolitical factors may cause Mr. Trump to reconsider or mitigate his approach to the Iran Nuclear Deal. Companies should prepare to respond quickly to any changes. … Continue Reading
On January 16, 2016, two NFL playoff games and a historic revision of U.S. foreign policy took place. Many of us enjoyed the first two (did you see that last-second touchdown pass?!) but did not pay close attention as the United States lifted many of its secondary sanctions against Iran. Even those normally attentive to … Continue Reading
By: Scott Maberry and Mark Jensen
People who practice U.S. economic sanctions law like to talk about how sanctions are policy-oriented, or an engine of U.S. foreign policy. Whereas some laws may be more opaquely political, economic sanctions and embargoes seem to express most bluntly how international leverage works through regulation. And yet, a few recent regulatory developments show that the direction that sanctions take is not always predictable.
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By: John M. Hynes
The U.S. Department of Treasury's Office of Foreign Assets Control ("OFAC") has issued welcome guidance for those wishing to provide personal communications services or software to individuals in Iran. On March 20, 2012, OFAC released interpretive guidance regarding the scope of the personal communications general and specific licenses found in Section 560.540 of the Iranian Transactions Regulations, 31 C.F.R. part 560 ("ITR"). On the same day, OFAC also revised the ITR definition of the term "entity owned or controlled by the Government of Iran".
While the personal communications licenses remain limited in scope, OFAC's new interpretive guidance should help exporters understand what specific services and software may be provided to individuals in Iran. … Continue Reading