Iran Threat Reduction and Syria Human Rights Act

By: Scott Maberry and Matthew Riemer

In the final weeks of May, the U.S. Government engaged in a flurry of Iran sanctions activity, showing a continuing commitment to identifying and penalizing persons who do business with Iran.

Oil, Petrochemical, and Aircraft Industries.

On May 31, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) imposed sanctions on entities and individuals that are part of, or have done business with, Iran’s international procurement and proliferation operations.  The targeted entities include branches of the Iranian government (e.g., the Islamic Revolutionary Guard Corps and the Ministry of Defense for Armed Forces Logistics), several Iranian petrochemical companies, and a group of corporations and individuals in Kyrgyzstan, Ukraine, and the United Arab Emirates that lease or sell aircraft to Iranian companies.  The sanctions were imposed pursuant to Executive Orders 13,382 (targeting proliferators and supporters of Iran’s weapons of mass destruction) and 13,599 (targeting the government of Iran).
Continue Reading OFAC Continues to Expand the Scope of Iranian Sanctions

By: Scott Maberry and Matthew Riemer

As we reported last month, the Obama administration continues to display a commitment to increasingly tough sanctions against Iran and its trading partners. Over the past few weeks, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) has published new regulations implementing certain sections of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”) and various Executive Orders.
Continue Reading Iranian Transactions and Sanctions Regulations Impose New Restrictions on U.S. Business in Iran

By: J. Scott Maberry and Matthew Riemer

In the months since the signing of the Iran Threat Reduction and Syria Human Rights Act (which we will stubbornly continue to refer to here as “ITRA”), the Obama administration has worked to implement tougher sanctions against Iran.  Although many of the ITRA regulations are not expected until early November, an Executive Order issued last week marked the beginning of a much stricter era of sanctions pursuant to ITRA, the Iran Sanctions Act of 1996 (ISA), and the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).
Continue Reading Sanctions on Foreign Subsidiaries Implemented Under Iran Threat Reduction Act