Iran Sanctions

News & Analysis as of

Still Serious About Sanctions: OFAC Settles Violations Involving Cuba and Iran

Lest U.S. companies think that Cuba and Iran are entirely open for business, a U.S. government settlement announced earlier this month with National Oilwell Varco, Inc. (NOV), a U.S. oilfield services company, will serve as a...more

Sanctions Update: Burma, Cuba, and Iran

Over the past month, substantial changes were made to several sanctions programs affecting Burma, Cuba, and Iran by President Obama and the Department of Treasury Office of Foreign Assets Control (OFAC)....more

Post-Election Outlook: A New, Unpredictable World

In a shock to investors and political analysts around the world, Donald J. Trump won the 2016 Presidential election, putting the Republican Party in charge of the White House and Congress for the first time in a decade. Even...more

Post-Election Congress Returns for Lame Duck Session What to Expect? - Updated

Last week, ML Strategies shared our thoughts on what to expect in the post-election lame duck Congress. The unknown factor at that point in time was who would be elected President on November 8th, which party would be in the...more

Sanctions in Energy: Russia and Iran

US and EU sanctions related to Russia and Iran have a direct and targeted impact on the energy sector. The sanctions regimes against Russia and Iran differ substantially and seem to be moving in different directions. In this...more

New Administration May Change Landscape of U.S. Trade and Export Policy (IRB No. 560)

Although it is impossible to tell whether the new Trump administration will follow through on its campaign promises to alter the landscape of U.S. trade with foreign countries, businesses should realize that the new...more

Towards a UK Investment Act?

Against the background of UK policy moving towards a more nationally-led trade and investment policy following this summer’s referendum, the new UK government is still in the process of establishing its policies regarding...more

Post-Election Congress Returns for Lame-Duck Session What to Expect?

Upon its return on November 14, the House is scheduled to be in session for 16 days during November and December, with the Senate scheduled for 20 days. Much of the legislative work of the lame-duck will occur after the...more

Sanctions Roundup: Third Quarter 2016 and Executive Order on Burmese Sanctions

OFAC, acting under the direction of President Obama’s Executive Orders, has lifted the economic and financial sanctions against Burma and Côte D’Ivoire. The revisions open these countries, and their financial markets, to...more

Red Notice Newsletter - October 2016

ANTICORRUPTION DEVELOPMENTS – DOJ Issues First-Ever Declinations Requiring Disgorgement of Profits to Resolve FCPA Violations - On September 29, 2016, the Department of Justice (DOJ) for the first time announced...more

Iran on Your Mind? The FAR Should Be, Too.

Over the past year, the big news for companies doing or considering business in Iran has been the scaling back of U.S. and EU economic sanctions. Many global businesses are now permitted to operate in this once prohibited...more

District Court Upholds Indictment of Turkish/Iranian Billionaire Charged with Evading US Economic Sanctions against Iran

U.S. District Court Judge Richard M. Berman denied a motion to dismiss the indictment in the closely followed criminal prosecution of Reza Zarrab, a Turkish/Iranian businessman charged with conspiring to evade U.S. economic...more

OFAC Provides Further Guidance On Iranian Sanctions

This month the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) updated its ‘Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA)...more

Those Three Little Words: OFAC’s Subtle Language Shift Could Create Sweeping Change on Iran Investment

Article Highlights: - Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks. - Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United...more

Treasury Department Issues Guidance Intended to Ease Dollar-Denominated Foreign Transactions with Iran

The United States Treasury Department’s Office of Foreign Asset Control (OFAC) amended its guidance on Iranian sanctions to clarify that some transactions with Iran by non-U.S. institutions are permitted, provided that such...more

OFAC Guidance on U.S. Dollar Transactions Involving Iran

On October 7, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published new guidance clarifying (a) circumstances under which non-U.S. financial institutions (FFIs) may engage in U.S. dollar...more

Red Notice Newsletter - September 2016

Former CEO of Harris Corporation’s Chinese Subsidiary Pays $46,000 to Settle Alleged FCPA Violations; No Charges for Company - On September 13, 2016, the Securities and Exchange Commission (SEC) issued a...more

Red Notice Newsletter - Chinese

LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases - Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more

Red Notice Newsletter - Russian

LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases - Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more

Red Notice Newsletter - August 2016

LATAM Airlines Agrees to Pay $22 Million to Settle FCPA Cases - Last month, LATAM Airlines (“LATAM”), based in Santiago, Chile, agreed to pay $22 million to settle parallel civil and criminal proceedings involving...more

Considerations for Travel to Iran to Explore Relaxed Trade Opportunities

Before booking your airfare, be mindful of these potential issues. In light of liberalized trade with Iran made possible by the Office of Foreign Assets Control’s (OFAC’s) General License H and the relaxation of US...more

OFAC General License Loosens Restrictions on Non-US Carrier Flights to Iran

On Friday, July 29, the US Office of Foreign Assets Control (OFAC) issued General License J under the Iranian Transactions and Sanctions Regulations (ITSR). This general license authorizes non-US airlines to fly US origin...more

Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New “General License J” authorizes many Boeing, Airbus, and...more

OFAC Cites Violations in Dealings with Specially Designated Nationals

Insurance companies and financial institutions are targeted. On August 2, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a Finding of Violation against two different insurance...more

Cleared for Takeoff: OFAC’s General License J Allows Boeing, Airbus and Other Aircraft to Land in Iran

On July 29, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued a new General License J (GL-J). GL-J authorizes the reexportation of certain civil aircraft on temporary sojourn to Iran,...more

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