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
11/7/2018
/ Blocking Statutes ,
Economic Sanctions ,
Energy Sector ,
EU ,
Exports ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
SDN List ,
Secondary Sanctions ,
Shipping ,
Special Purpose Vehicles ,
Trump Administration
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
8/9/2018
/ Blocking Statutes ,
EU ,
Executive Orders ,
Financial Institutions ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down ,
Withdrawal
The U.S. yesterday commenced the phased re-introduction of its pre-JCPOA extra-territorial sanctions in relation to Iran – with some measures applying immediately, and others from 5 November. The EU has condemned U.S....more
8/9/2018
/ Blocking Statutes ,
China ,
Economic Damages ,
EU ,
European Commission ,
Extraterritoriality Rules ,
Financing ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Member State ,
Notice Requirements ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secondary Sanctions ,
Trump Administration
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
7/19/2018
/ Blocking Statutes ,
Bonds ,
Cryptocurrency ,
Debt Buyers ,
Debt-Equity ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
EU ,
Financial Markets ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Russia ,
SDN List ,
Secondary Sanctions ,
Syria ,
Trump Administration ,
Ukraine ,
Venezuela
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
Following the U.S. decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA) and reimpose sanctions on Iran, the EU has confirmed its full commitment to keep the agreement alive for the remaining parties, as...more
6/13/2018
/ Blocking Statutes ,
EU ,
European Commission ,
Exemptions ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Waivers ,
WTO
President Trump announced today, May 8, 2018, that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”), the Iran nuclear deal implemented in January 2016. In connection with the...more
On 12 May 2018, US President Trump will decide whether or not to renew the US sanctions relief in relation to Iran. Declining to do so would put the US in breach of, and amount to US withdrawal from, the JCPOA, the Iran...more
4/23/2018
/ China ,
EU ,
France ,
Germany ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Negotiations ,
Nuclear Power ,
Russia ,
Secondary Sanctions ,
Trump Administration
In 2017 there were a number of major sanctions developments in the EU and the US, with implications for businesses both in terms of keeping their compliance processes effective, and in terms of what to do if breaches are...more
2/6/2018
/ Anti-Money Laundering ,
CAATSA ,
Compliance ,
Economic Sanctions ,
EU ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Nuclear Power ,
Office of Financial Sanctions Implementation (OFSI) ,
Russia ,
Sovereign Debt ,
UK ,
UK Brexit ,
Venezuela
Despite the easing of sanctions on Iran on 16 January under the Joint Comprehensive Programme of Action (JCPOA), some prohibitions and licensing requirements continue to apply to EU businesses. These are summarised below,...more
1/19/2016
/ Dual Use Goods ,
EU ,
Exports ,
Imports ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Licenses ,
Military End Use ,
Military Goods ,
Nuclear Power ,
Procurement Guidelines ,
UN Security Council
On Saturday, 16 January 2016, the International Atomic Energy Association (IAEA) submitted a report to the United Nations Security Council (UNSC) certifying that Iran has satisfied its obligations under the Joint...more
Public officials from the United States increasingly are making public statements regarding the likelihood that “Implementation Day” – the day on which many US and EU sanctions against Iran will be eased – will arrive in the...more
The United States and European Union took preparatory steps on 18 October 2015 to begin fulfilling their commitments to suspend certain sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”)...more
10/22/2015
/ Adoption Day ,
Amending Regulation ,
EU ,
Financial Transactions ,
Implementation Day ,
Insurance Litigation ,
International Atomic Energy Agency ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Metals ,
Military Goods ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Shipping ,
UN Security Council
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
9/14/2015
/ Adoption Day ,
Asset Freeze ,
EU ,
Implementation Day ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Nuclear Weapons ,
Political Parties ,
UN Security Council ,
United Nations
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