Iranian Transactions Regulations (ITR)

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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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Continue Reading OFAC Gets Hot, Bothered on Iran and Cuba: How Economic Sanctions Work Today

By: Thad McBride, Reid Whitten, and Cheryl Palmeri

On May 21, the U.S. Treasury Department Office of Foreign Assets Control (OFAC) announced a small but noteworthy enforcement settlement: a fine against a U.S. investment fund because the foreign subsidiary of that fund purchased Iranian securities.  It appears that OFAC’s enforcement action was not based on “facilitation” of a prohibited transaction with Iran, but rather on the U.S. parent’s failure to maintain sufficient controls to prevent its foreign subsidiary from conferring an economic benefit to Iran.  As a result, the U.S. investment manager, Genesis Asset Managers LLP (GAM US) will pay a civil penalty of $112,500.   …
Continue Reading OFAC’s (Very) Long Arm: GAM Settlement May Illustrate the ITR’s Expanding Reach