News & Analysis as of

Iran Sanctions Compliance

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

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

Red Notice Newsletter - February 2017

Acting SEC Chief Limits Subpoena Authority to Enforcement Division Acting Director - On February 15, 2017,The Wall Street Journal reported that the acting Chair of the Securities and Exchange Commission (SEC), Michael...more

Sanctions Updates: Iran, Myanmar (Burma) and Cuba

by Michael Volkov on

With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more

Top Compliance Issues Facing Manufacturers in 2016

by Foley & Lardner LLP on

In the last several years, the U.S. has been aggressively enforcing laws governing exports and international conduct. This is amply illustrated by the continuing imposition of large penalties on multinational companies for...more

The Changes to Iran Sanctions and Compliance Challenges

by Michael Volkov on

Putting aside the politics surrounding the Iran Nuclear Deal, the exchange of prisoners and other hot button political issues surrounding Implementation Day and the change in US-Iran relations, the new Iran sanctions create a...more

Checking In on Sanctions Enforcement

by Michael Volkov on

The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement...more

International Trade Alert: Iranian sanctions and a new Office of Financial Sanctions Implementation

by DLA Piper on

Under the terms of the agreement, EU and US sanctions relief will be provided through the suspension and eventual termination of sanctions measures, beginning only if and when the International Atomic Energy Agency verifies...more

New York-Based Marine Insurer Settles Potential U.S. Sanctions Violations

by Carlton Fields on

As if to provide a not-too-subtle reminder to insurers of the applicability of U.S. trade sanctions to their businesses, the Treasury Department’s Office of Foreign Asset Control (OFAC) announced on August 6, that a New...more

Insurers Take Notice: Don’t Become a Casualty of Trade Sanctions Violations!

by Davis Wright Tremaine LLP on

The U.S. Department of Commerce’s Office of Foreign Assets Control (OFAC) announced that Navigators Insurance Company, which is headquartered in New York and specializes in marine insurance and related lines of business,...more

Iran – Don’t Forget the General License!

by 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

Iranian Nuclear Accord Reached, But Specific Implementation of Meaningful Sanctions Relief Will Not Be Immediate

by K&L Gates LLP on

On July 14, 2015, the “P5+1” nations (the United States, China, France, Germany, Russia, and the United Kingdom), together with the European Union and the Islamic Republic of Iran (“Iran”), reached a Joint Comprehensive Plan...more

Impact of Iran Accord on International Business - Briefing the "C" Suite on the Joint Comprehensive Plan of Action with Iran

by Holland & Knight LLP on

On July 14, 2015, the United States, France, China, Russia, the United Kingdom, Germany and the European Union (EU) entered into the Joint Comprehensive Plan of Action (JCPOA) with Iran after years of difficult negotiations....more

Trade & Manufacturing - July 2015

by King & Spalding on

In This Issue: - Update on Trade Promotion Authority and Companion Trade Bills: A Lot Can Happen In Washington In 34 Days - Congress Allows Export-Import Bank Charter to Expire, for Now - WTO Finds That COOL Is...more

Corporate Investigations & White Collar Defense - May 2015

It’s an Absolute Privilege to Meet You! Texas Supreme Court Rules That Internal Investigation Report Provided by Shell Oil to DOJ Enjoys “Absolute Privilege” - Why it matters: On May 15, 2015, the Texas Supreme Court...more

Senate adopts Iran Nuclear Agreement Review Act

by Dentons on

On May 7, 2015, the US Senate voted 98-1 to adopt the Iran Nuclear Agreement Review Act of 2015 (the "Act"). The Act is the culmination of months of legislative maneuvering and a debate over foreign policy and separation of...more

U.S. Government Announces Significant Sanctions Enforcement Actions Against Schlumberger and PayPal

by Dechert LLP on

The U.S. Government announced two major sanctions enforcement actions this week that reinforce the compliance challenges faced by both U.S. companies with international activities and non-U.S. companies subject to U.S....more

What’s New for the 2014 Proxy Season

by Dorsey & Whitney LLP on

Unlike in past years, there are no new disclosure requirements which need to be reflected in this year’s proxy statement; however, with ongoing shareholder activism and the desire of companies to communicate effectively with...more

Why Eat Your Words When You Can Eat a Peach?

by Thomas Fox on

Taken to the woodshed or when should a company have to eat its own words? Remember when President Reagan’s Director of the Office of Management and Budget, David Stockman, was ‘taken to the woodshed’ by White House Chief of...more

Trade & Manufacturing Alert - February 2013

by King & Spalding on

In This Issue: - Special Feature: Book Review - Innovation Economics: The Race for Global Advantage - U.S. Focuses On IP Protection Failure In Foreign Markets, Requests Comments - U.S. Trade Officials Meet with...more

New Reporting Requirements Under the Iran Threat Reduction and Syria Human Rights Act of 2012

by Smith Anderson on

On August 10, 2012, the United States delivered its latest economic blow to Iran by enacting the Iran Threat Reduction and Syria Human Rights Act of 2012. U.S. companies have long been forbidden from engaging in most...more

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