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End of the Road: U.S. Sanctions on Iran Come Back Into Effect

On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more

Iran Sanctions – U.S. Reimposes Sanctions After JCPOA Withdrawal, First Measures Come Into Effect

As expected, following his May 8, 2018, decision to withdraw the United States from the Joint Comprehensive Plan of Action (“JCPOA”), President Trump signed a new Executive Order (“E.O.”) on August 6, 2018, formally...more

Financial Services Quarterly Report - Second Quarter 2018: Current U.S. Sanctions Against Russia, Venezuela and Iran

International sanctions are a major compliance challenge for companies worldwide. The regulatory risks associated with economic sanctions, asset-freezing measures and trade embargoes are not new, but they continue to grow in...more

The United States Tightens Iran Sanctions by Revoking Authorizations

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has tightened Iran sanctions. Specifically, OFAC revoked authorizations that (1) allowed foreign subsidiaries of U.S. companies to do business in Iran;...more

BREAKING: President Trump Signs Russia/Iran/North Korea Sanctions Bill

Yesterday, President Trump signed H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act,” enacting into law limited additional sanctions against Russia and, critically, restricting his ability to suspend or...more

House Passes Bill Authorizing Additional Sanctions Against Russia, North Korea and Iran

After weeks of discussion and procedural uncertainty, the U.S. House of Representatives passed new legislation by a vote of 419–3 that, if enacted into law, will strengthen existing sanctions against Russia and also impose...more

Iran Deal “Clears” Congress, But No Sanctions Relief Yet

On September 10, 2015, Senate Democrats in the U.S. Congress blocked a vote on a widely anticipated resolution to reject the Joint Comprehensive Plan of Action (“JCPOA”) regarding Iran’s nuclear program. On September 11, the...more

Nuclear Agreement with Iran Announced: Significant Easing of Iran Sanctions in Sight, but Only Outside of the United States

Iran and the P5+1 countries (United States, Russia, China, United Kingdom, France and Germany) on 14 July 2015 announced their agreement on a comprehensive plan under which certain international sanctions against Iran will be...more

Two Non-U.S. Banks Agree to Pay Penalties Totaling $160 Million for Violations of U.S. Sanctions Laws Resulting from Omnibus...

Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more

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