News & Analysis as of

Due Diligence Iran

Pillsbury Winthrop Shaw Pittman LLP

Significant Changes to the SBIR and STTR Programs

In the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Extension Act of 2022, Congress reauthorized these programs for another three years and added new requirements to reduce foreign...more

Holland & Knight LLP

2023 NDAA Tightens Controls on Chinese Semiconductors in Government Contractor Supply Chains

Holland & Knight LLP on

President Joe Biden signed into law the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (2023 NDAA or Defense Bill) on Dec. 23, 2022. The Defense Bill, which passed the U.S. House of Representatives on...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Global Compliance Updates - November 2nd - 3rd, 5:55 pm - 8:15 pm GST

Compliance teams looking to stay ahead of the changing landscape need to be up to date on the latest developments. Join us for Global Compliance Updates in collaboration with the DIFC Academy, on 2–3 November 2021. This...more

ArentFox Schiff

Sleeper Trump Rule on ‘Military-Intelligence End Uses or Users’ Goes Into Effect

ArentFox Schiff on

Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule. In an interim rule published on, January 15, 2020, the Department of...more

Lowenstein Sandler LLP

U.S. Government Issues Updated Sanctions Warning to Maritime Shipping Community; Recommends Best Practices to Mitigate Risk

Lowenstein Sandler LLP on

On May 14, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of State, and the U.S. Coast Guard issued a Sanctions Advisory for the Maritime Industry, Energy and Metals...more

K2 Integrity

FATF Calls for Reimposition of Countermeasures on Iran

K2 Integrity on

The Financial Action Task Force (FATF) on February 21, 2020, reintroduced its call for countries to impose countermeasures to protect themselves from illicit finance threats emanating from Iran. The call for countermeasures...more

Ballard Spahr LLP

FinCEN Issues Advisory on Foreign Jurisdictions with AML Deficiencies

Ballard Spahr LLP on

On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more

Hogan Lovells

U.S. government announces enhanced due diligence process for humanitarian trade with Iran and identifies Iran as a jurisdiction of...

Hogan Lovells on

On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran. Foreign governments and foreign financial institutions...more

Ballard Spahr LLP

FinCEN Identifies Iran as a Jurisdiction of Primary Money Laundering Concern

Ballard Spahr LLP on

On October 25, 2019, FinCEN issued a final rule imposing the Fifth Special Measure against the Islamic Republic of Iran as a “jurisdiction of primary money laundering concern” (“Final Rule”) under Section 311 of the USA...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Puts Companies on Notice: Due Diligence in Iran Can Trigger Sanctions Violations

• This enforcement action highlights the heightened sanctions compliance and enforcement risk that companies face when engaging third-party consultants to perform due diligence on counterparties. U.S. persons must make clear...more

Perkins Coie

Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

Perkins Coie on

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more

Thomas Fox - Compliance Evangelist

Four Things Compliance Practitioner Should Know About the Eurasian Economic Union

Four Things Compliance Practitioner Should Know About the Eurasian Economic Union - An effective Compliance risk management at emerging markets for any business significantly depends on timeous observation of changes in...more

Williams Mullen

“Reason To Know” – A Chilling Term For Exporters

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It’s a simple question – if a U.S. exporter sells its product to a foreign customer, and the customer resells the product to a prohibited country such as Iran, can the U.S. exporter have liability for an export violation? ...more

Kelley Drye & Warren LLP

Epsilon Case Highlights the Need for Sanctions Due Diligence on Resellers

As global companies begin to reenter the Iranian market, a decision issued by the U.S. District Court for the District of Columbia is an important reminder that resellers and distributors can generate liability for U.S....more

Baker Donelson

Iran – Don’t Forget the General License!

Baker Donelson on

Iran entered into a historic nuclear agreement with the U.S. and other world powers on July 14th 2015. The agreement will allow the licensing of the export, re-export, sale, lease or transfer to Iran of commercial passenger...more

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