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 opportunity for non-U.S. aircraft owners and operators. However, a series of complex conditions may complicate ground handling agreements, damp or dry lease arrangements, code sharing, or other transactions related to providing service to Iran.
Continue Reading Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On June 20, 2016, you will be able to take a non-stop flight from Tehran to Paris . . . but you probably shouldn’t.

According to its website, the Iranian airline Mahan Air will add the City of Lights to the list of European destinations it is already serving, including Athens, Copenhagen, and Dusseldorf. What makes the current and proposed Mahan routes interesting to regulatory experts (read: nerds) is that Mahan Air is on the U.S. Treasury’s Specially Designated Nationals (SDN) list. According to the Treasury’s Office of Foreign Assets Control (OFAC), Mahan Air has moved troops and equipment for the Iranian Revolutionary Guard Corps and has provided support and transport to the Assad regime in Syria.


Continue Reading Flying the Too-Friendly Skies? Europe Opens Routes for Sanctioned Iran Airline

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 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

On August 30, 2015, the Washington Post broke a story that the Obama administration is developing a package of economic sanctions that will target Chinese companies and individuals who have benefitted from cybertheft. The new sanctions would come at a time when commerce between the two countries is thriving, but political relations are strained.
Continue Reading Keep Your Frenemies Close: Proposed China Sanctions and the Price of Escalation

Cyber threats are one of the U.S.’s top security threats.  In just the past year, there has been a significant increase in the frequency, scale and sophistication of cyber intrusions and attacks – many of them originating overseas – which have targeted U.S. businesses.  On April 1, 2015, the President announced a new tool to combat the most significant cyber threats to the national security, foreign policy and economy of the United States.  
Continue Reading U.S. Authorizes Targeted Sanctions Against Overseas Cyber Threats

On March 12, 2015, Commerzbank AG, Germany’s second largest bank and a global financial institution, agreed to pay $1.45 Billion (yes, with a “B”) in forfeitures and fines to the U.S. Government for violating U.S. sanctions against Iran and Sudan. The amount paid by Commerzbank under the settlement will not be shocking to those who read our reporting on the BNP Paribas penalty of $8.9 Billion (again, that is a “B”) for similar sanctions violations.
Continue Reading The Broader Problem: European Bank Creates an Easy Catch for the Long Arm of U.S. Jurisdiction