Sanctions Round-Up: Fourth Quarter 2013

As 2013 drew to a close, a potentially groundbreaking agreement was reached with Iran regarding its nuclear program, leading to much speculation about how certain sanctions might be suspended, and under what conditions. While the majority of this year’s actions focused on Iran, OFAC continued to announce a number of designations made under the other US sanctions programs, including those targeting terrorism, transnational criminal organizations, and narcotics traffickers. OFAC also announced a handful of settlements stemming from apparent sanctions-related violations, including the largest-ever settlement with a non-financial institution. Finally, the EU took steps to re-blacklist a number of persons whose designations had previously been annulled by EU courts while those courts continued to review additional contested designations.

Interim Agreement Reached with Iran -

On November 23, Iran and the five permanent members of the UN Security Council (China, France, Russia, the United Kingdom, and the United States), and Germany (collectively known as the P5+1), reached a tentative interim agreement regarding Iran’s nuclear program. The Joint Plan of Action (JPA) proposes that Iran be granted contingent economic relief from certain US and EU sanctions in exchange for taking verifiable steps to limit its nuclear activities. The JPA does not itself modify any existing sanctions laws and regulations nor authorize any specific transactions or trade with Iran. Further, the sanctions relief measures will be temporary and reversible, and no sanctions will be suspended until Iran complies with its obligations under the JPA.

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