Tag Archives: Iran

Today, President Trump Decertified the Iran Deal and Announced Tougher Sanctions on Iran

HERE WE ANSWER A FEW OF THE QUESTIONS THAT YOU MAY HAVE What does decertification mean? For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear program in exchange for relief from U.S. … Continue Reading

One Year From Now, You May Be Out of Iran: Trump Administration Policy and the Timeline for Snapback

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

In the Chaos of (Trade) War, Where Does Your Company Find Peace?

On July 27, 2017, the U.S. Congress sent to President Trump’s desk a bill that imposes new financial sanctions against Russia, Iran, and North Korea. It appears nearly certain that the president will sign that bill, now called the “Countering America’s Adversaries Through Sanctions Act” (CAATSA). Edit: President Trump signed the bill on August 2, … Continue Reading

Predicting the Unpredictable: Will President Trump Tear Up the Iran Nuclear Deal?

As a candidate for President, Donald J. Trump was widely reported to despise the Iran nuclear agreement, which is known as the Joint Comprehensive Plan of Action. As President, he responded to reports of Iranian missile tests by putting Iran “on notice.” While observers have speculated whether that portends a naval escalation in the Persian … Continue Reading

The Table Flip: Trump, the Iran Nuclear Deal, and American Business

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

Those Three Little Words: OFAC’s Subtle Language Shift Could Create Sweeping Change on Iran Investment

Article Highlights: Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks. Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United States. OFAC draws a clearer line with respect to the use of Iran-related funds. After the Iran nuclear agreement, as non-U.S. companies entered into newly-permitted … Continue Reading

Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New  “General License J” authorizes many Boeing, Airbus, and other civil aircraft containing U.S.-origin materials to fly to Iran on “temporary sojourn.” The General License provides a great … Continue Reading

Buying Russian Bonds: Risky Business or Safe Bet?

In late May, The Russian Federation issued its first sovereign bond since the Ukraine crisis in 2014. The sole organizer of the bond is VTB Capital, an arm of VTB Bank, Russia’s second largest financial institution. Both VTB Capital and VTB Bank are subject to sectoral sanctions. According to published reports, the 10-year bond is … Continue Reading

New Business Opportunities in Iran! But Who Will Be Your Banker? Non-U.S. Banks Hesitant to Process Lawful Iran Transactions…and for Good Reason

Highlights: Sanctions relief presents new business opportunities with Iran Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies The line between permitted and prohibited financial transactions by non-U.S. banks is not clear Careful advice of counsel is critical… Continue Reading

Airplanes, Pistachios, and a New Burger Joint in Tehran: What Changes for the United States Under Lighter Iran Sanctions

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

A Break From the Past: Historic Deal with Iran Marks A New Day in U.S.-Iran Relations

Today, President Obama announced a landmark agreement with Iran designed to prevent Iran from obtaining a nuclear weapon in exchange for lifting sanctions that have retarded the country’s development for the decades since the revolution. The agreement is the result of 20 tough months of negotiations among Iran and the so-called P5+1 (the United States, … Continue Reading

UPDATE: Iran Nuclear Deal

Iran and the Western powers have agreed to agree again. On April 2, 2015, the so-called P5+1 (the United States, the UK, China, France, and Russia) along with the EU, have joined Iran in announcing that they have reached a set of broad “parameters” to be negotiated in detail between now and June 30, 2015, regarding … Continue Reading

Paying the Piper: PayPal Inc. Settles Sanctions Violations with OFAC for $7.7 Million

On March 25, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that PayPal Inc. (“PayPal”) agreed to pay $7.7 million to settle 486 violations of U.S. economic sanctions.  According to OFAC, for several years until 2013, PayPal, one of the world’s largest electronic payment companies, did not have adequate compliance processes … Continue Reading

Round Two: Prosecutors Reopen Bank Settlements

With our political system suffering from a growing chasm down party lines, our public servants seem to be increasingly vulnerable to public pressure.  Politicians scramble to fight for whatever cause du jour will garner them the most support.  And lately, no political act is guaranteed to please Main Street quite so much as blaming the … Continue Reading

BNP Paribas and La Résistance: Why Compliance is not Capitulation and Cooperation Could Save an Economy

I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of time for leisure and family. Indeed, most attempts by the country to preserve la vie Française are idealistic efforts to protect what … Continue Reading

Iran Sanctions: 2013 and Beyond

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 … Continue Reading

The European Court of Justice Overturns, Unfreezes EU Iran Sanctions

By: Mark Jensen In a series of recent rulings, the European Court of Justice overturned economic sanctions issued by the Council of the European Union (EU) on several Iranian banks and shipping lines.  On September 6 and 16, 2013, the Court halted sanctions on Persia International Bank plc, Bank Refah Kargaran, Export Development Bank of Iran, Post Bank Iran, Iranian Offshore Engineering & Construction Co., Iran Insurance Company, Islamic Republic of Iran Shipping Lines (IRISL), Khazar Shipping Lines, and Good Luck Shipping.  The EU had sanctioned these entities for their support of nuclear proliferation activities in Iran, but the Court determined that the EU lacked sufficient evidence to introduce such sanctions.  The cases are notable for their effect on global sanctions against Iran, although it seems unlikely that U.S. sanctions against Iran would be lifted on similar grounds.… Continue Reading

ALERT: Clarifications of the Iranian Sanctions Regulations

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

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

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

Sanctions on Foreign Subsidiaries Implemented Under Iran Threat Reduction Act

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
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