U.S. Office of Foreign Assets Control (OFAC)

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

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 most noteworthy Iran development in 2013 – a tentative nuclear agreement between Iran and six world powers – proved that diplomacy may be an alternative to ever-tightening sanctions.  With that single development came the possibility, remote though it may still be, that Iran’s economy could someday reopen to international business.

Here, we look back at important developments of 2013 and contemplate what 2014 might hold for U.S. sanctions on Iran.


Continue Reading Iran Sanctions: 2013 and Beyond