News & Analysis as of

Iran Sanctions

Trump Administration Re-Certifies Iranian Compliance with Nuclear Agreement; Imposes Sanctions on Additional Entities for Other...

by Hogan Lovells on

On July 17, the Department of State communicated to Congress that Iran remains in compliance with its obligations under the Joint Comprehensive Plan of Action (JCPOA), the nuclear agreement reached over Iran’s nuclear program...more

Senate Passes Russia and Iran Sanctions Legislation

by Bass, Berry & Sims PLC on

On June 19, 2017, the U.S. Senate overwhelmingly passed a bill mandating sanctions against Russia and Iran and a 30-day congressional review period should the president attempt to reduce those sanctions....more

Lessons in Civil Forfeiture and Attachment: U.S. May Seize 650 Fifth Avenue

by Ballard Spahr LLP on

On June 29, dual trial verdicts in the Southern District of New York paved the way for the government to seize 650 Fifth Avenue, a 36-story building in Manhattan valued at up to $1 billion (“the Property”). The defendants,...more

Sanctions Round Up: First Half

by Shearman & Sterling LLP on

The first six months of the Trump Administration saw several notable developments for US sanctions, with particular implications for Russia and Iran. The Administration also declared a shift in US policy toward Cuba. ...more

Red Notice Newsletter - June 2017

ANTICORRUPTION DEVELOPMENTS - Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program - On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more

Rare Court Case Sheds Light on U.S. Sanctions Enforcement

by Bass, Berry & Sims PLC on

It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more

Iran and Russia Sanctions Pass US Senate

by Hogan Lovells on

Last week, the U.S. Senate acted to pass both new Iran and Russia sanctions by large bipartisan margins. The House of Representatives has not yet acted on either piece of legislation. We anticipate that Congress will...more

OFAC’s Broad Latitude To Impose Iran Sanctions Affirmed by D.C. Circuit

by Baker Donelson on

A D.C. Circuit Court of Appeal’s panel recently issued a key opinion affirming the U.S. Treasury Department’s broad ability to enforce sanctions regulations through its Office of Foreign Assets Control (“OFAC”). While the...more

Senate Bill Expands Sanctions on Russia and Iran

On June 15, 2017, the Senate passed the Countering Iran’s Destabilizing Activities Act of 2017 (S.722) by a vote of 98-2. Included with the bill is a significant Russia sanctions amendment, the Countering Russian Influence...more

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

by 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

What’s New in Washington: 10 Things You Need to Know

Despite the headlines coming out of Washington, Congress continues to move forward in regular fashion, discussing and acting upon key issues, such as funding the government, addressing the need to raise the debt ceiling and...more

Sanctions Penalty Reviewed By The D.C. Circuit Reversing $4M Penalty

by Fox Rothschild LLP on

Last week, the D.C. Circuit affirmed the U.S. Treasury Department’s Office of Foreign Assets Control’s (“OFAC”) wide latitude to impose Iran sanctions, but it set aside a $4.07 million penalty against car accessory seller...more

Something Borrowed, Something New: An Update on Recent Treasury and State Department Actions: Iran, Russia, Syria and the...

by Hogan Lovells on

While much attention has been focused on the Trump Administration's recent actions targeting imports of metals, lumber, and other commodities, the Administration has also steadily ramped up its activities in the trade...more

Dealing with Violations in Export and Import Transactions

by Williams Mullen on

You are the general counsel or CEO of your company. Your compliance manager comes into your office and tells you that he/she may have discovered an export violation within the company. Or perhaps you have received a directed...more

US Announces Review of Iran Nuclear Deal

by WilmerHale on

On April 18, 2017, the State Department certified to Congress that Iran was in compliance with its obligations under the Joint Comprehensive Plan of Action (JCPOA) between the United States, Iran, and the P5+1 nations. It...more

TD Bank and Sanctions Violations

by Michael Volkov on

Sanctions enforcement continues to be a significant risk. With the focus on unraveling elaborate corporate ownership schemes, the risk of conducting business with sanctioned individuals or entities is increasing....more

The Long Road: Boeing Continues the March into Iran

by Bass, Berry & Sims PLC on

- Boeing announces deal to sell aircraft to Iran Aseman - The deal was apparently authorized by the U.S. Treasury Department, but Congressional foes fight to block it - If the deal goes through, further loosening of...more

Red Notice Newsletter - March 2017

Anticorruption Developments - SEC Chairman Nominee Jay Clayton Receives Confirmation Hearing - On March 23, 2017, SEC Chairman Nominee Jay Clayton testified before the Senate Banking Committee at his confirmation...more

Flash update: trade compliance

by DLA Piper on

This week has seen two important developments in relation to the UK and EU legal and regulatory framework governing trade with Iran and Russia: - The European Court of Justice (the ECJ) has clarified a number of points...more

Potential Options for U.S. Sanctions on Iran Under the Trump Administration

by Jones Day on

In response to reports that Iran conducted a ballistic missile test launch in February 2017, a former senior U.S. government official announced—and President Trump later echoed over Twitter—that the United States is...more

Lessons from the Historic ZTE Enforcement Action

by Bass, Berry & Sims PLC on

On March 7, 2017, Chinese telecommunications company, Zhongxing Telecommunications Equipment Corp. (ZTE), signed on to three separate settlement agreements with the United States, agreeing to pay $892 million for violations...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Eddie Lampert’s Sears mega-gamble appears to finally be catching up with him. Or the store, at least. Mr. Lampert, it seems, will come out not as worse for the wear as one might have expected....more

Predicting the Unpredictable: Practical Steps for International Business Under the Trump Administration

President Trump’s successive executive orders restricting immigration caught many people off guard, and many businesses had to scramble to react. But we propose that predicting the future is not as challenging under the new...more

ZTE Settlement Highlights Broad Extraterritorial Application of U.S. Sanctions and Export Controls to Non-U.S. Companies

On March 7, U.S. authorities settled criminal and civil proceedings involving Zhongxing Telecommunications Equipment Corporation and certain of its affiliates ("ZTE"). ZTE is the largest publicly traded telecommunications...more

Predicting the Unpredictable: Will President Trump Tear Up the Iran Nuclear Deal?

As a candidate for President, Donald J. Trump was widely reported to despise the Iran nuclear agreement, which is known as the Joint Comprehensive Plan of Action. As President, he responded to reports of Iranian missile tests...more

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Cybersecurity

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