Iran Sanctions

News & Analysis as of

Obama Administration Issues Changes to Iran Sanctions Regulations That Benefit Exporters of Medicine, Medical Devices and...

On December 23, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a number of changes to the Iranian Transactions and Sanctions Regulations (“ITSR,” 31 C.F.R. Part 560) that expanded the...more

Iran and Russia Sanctions Programs Under a Trump Administration–What to Expect

In the final weeks of December, President Obama amended sanctions to both the Iran and Russia programs. These changes further relaxed sanctions on Iran while they tightened sanctions on Russia. Yet, just three days from the...more

"OFAC Eases Restrictions on the Export of Medical Devices to Iran"

On December 22, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to the general license (GL) that authorizes the export or re-export of certain medical devices to Iran....more

It’s Annual Report Time—Recent Developments and Trends for the Preparation of Form 20-F

It is now time for a large number of foreign private issuers to prepare their annual reports on Form 20-F. For companies with a calendar year-end, the Form 20-F must be filed with the U.S. Securities and Exchange Commission...more

Extension of Iran Sanctions Act: For Now, A Symbolic Act

On December 1, the United States Congress voted overwhelmingly to extend the Iran Sanctions Act, which was set to expire on December 31, for 10 more years. Between the two chambers, there was only one vote cast against the...more

OFAC Eases Restrictions on Medical and Agricultural Exports to Iran

On December 23, 2016, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued a final rule amending the Iranian Transactions and Sanctions Regulations (ITSR) to expand the scope of permissible exports and...more

Enforcement Trends: Sanctions and International Risk (Transcript)

How will the regulatory and enforcement landscape change under a new Presidential administration? In this podcast, Michael Casey and Alex Rene of Ropes & Gray’s government enforcement practice group discuss the potential...more

Legal Bases for Iran Sanctions, Cuba Sanctions, and NAFTA

How easily can the Trump administration change the status quo? The International Emergency Economic Powers Act (IEEPA), 50 U.S.C §§1701-1707 enacted October 28, 1977, authorizes the US president to broadly regulate...more

OFAC Expands Iran-Related Authorizations for Medicine, Medical Devices and Agricultural Commodities

On December 23, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Final Rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR) to expand the...more

Happy New Year: OFAC Expands Exports of Medical Devices to Iran

Effective December 23, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR) to expand the scope of medical devices that can be exported to...more

New OFAC Guidance Offers Clarity on Operations Involving Iran

On December 15, 2016, the Office of Foreign Assets Control (OFAC) provided updated guidance on what companies can expect in the event of the “snapback” of sanctions under the Joint Comprehensive Plan of Action (JCPOA). ...more

OFAC Provides Prospective Guidance on Potential “Snap-Back” of Iran Sanctions

On December 15, 2016, the Office of Foreign Assets Control (“OFAC”) in the Department of the Treasury amended its Frequently Asked Questions guidance document (“FAQs”) regarding the Joint Comprehensive Plan of Action...more

2017 Key Trade Issues: U.S. Embargoes and Economic Sanctions on Iran, Russia, and Cuba

U.S. embargoes and economic sanctions on countries such as Iran, Russia and Cuba were discussed at length by both candidates during the 2016 Presidential campaign, and President-Elect Trump has stated that he intended to...more

Happy (End of the) Holiday: OFAC Signals Potential Iran Sanctions Snapback

In what may be a harbinger of things to come, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has issued new guidance regarding what may occur if the United States re-implements economic sanctions...more

Iran Sanctions: OFAC Provides—at Least for Now—Assurances of a Wind-Down Period in Case of Snap-Back

On December 15, 2016, the Office of Foreign Assets Control revised its Frequently Asked Questions guidance that concerns the re-imposition of sanctions in the event of a sanctions snapback under the Joint Comprehensive Plan...more

Lifting of certain US sanctions on Iran – impact on investigations

Since the easing of certain US sanctions on Iran earlier this year, companies have continued considering potential avenues for operating in or with Iran. Subsequent guidance from the US Department of Treasury's Office of...more

Presidential Pulse: 10 Key Ways the Trump Administration May Impact The Way You Do Business in 2017

Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more

The Table Flip: Trump, the Iran Nuclear Deal, and American Business

- A President Trump will have authority to reinstate sanctions lifted by the Iran Nuclear Deal as well as revoke certain authorizations provided for business with Iran. - Several economic and geopolitical factors may...more

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

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