News & Analysis as of

Iran Sanctions Foreign Subsidiaries

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - January 2024

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On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more

The Volkov Law Group

DOJ Resolves First Corporate Sanctions Case Involving Iran Sanctions Program

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The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more

Jones Day

OFAC Dramatically Expands Reporting Obligations

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Ambiguous, undefined terms create uncertainty and confusion, including whether owned or controlled subsidiaries of U.S. companies outside the United States are subject to this reporting requirement. On June 21, the...more

The Volkov Law Group

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

The Volkov Law Group on

On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”).  (Available here).  Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more

WilmerHale

OFAC Crystallizes Expectations for Sanctions Compliance

WilmerHale on

On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more

The Volkov Law Group

Stanley Black and Decker Settles OFAC Enforcement Action for $1.9 Million

The Volkov Law Group on

Stanley Black and Decker (“Stanley”) and its Chinese subsidiary Jiangsu Guoqiang Tools Co. (“GQ”) agreed to pay approximately $1.9 million to settle OFAC charges that it violated the Iran Sanctions Program. The OFAC...more

The Volkov Law Group

OFAC Begins to Re-Impose Iran Sanctions and Expands Reach of Previous Sanctions

The Volkov Law Group on

The Trump Administration issued a new executive order on August 6, 2018, in order to reimpose the first tranche of the Iran sanctions lifted by the former Joint Comprehensive Plan of Action (“JCPOA”). ...more

Dechert LLP

The United States Tightens Iran Sanctions by Revoking Authorizations

Dechert LLP on

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has tightened Iran sanctions. Specifically, OFAC revoked authorizations that (1) allowed foreign subsidiaries of U.S. companies to do business in Iran;...more

Husch Blackwell LLP

OFAC Officially Revokes Iran General Licenses And Signals Aggressive Enforcement Posture

Husch Blackwell LLP on

On June 27, 2018, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) officially revoked General Licenses H and I. General License H previously allowed foreign owned or controlled subsidiaries of...more

Perkins Coie

Sanctions Update: Rewind Your Iran Compliance Policy to January 2016

Perkins Coie on

The United States will reimpose sanctions against Iran to implement President Donald Trump’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), a multilateral agreement under which Iran agreed to curb...more

Jones Day

Trump Announces New Iran Strategy, Decertifies Iran's Compliance with Iran Nuclear Deal

Jones Day on

On Friday, October 13, 2017, President Trump announced that he would not certify that the suspension of sanctions pursuant to the Joint Comprehensive Plan of Action ("JCPOA") (commonly known as the Iran Nuclear Deal) is...more

Sheppard Mullin Richter & Hampton LLP

Today, President Trump Decertified the Iran Deal and Announced Tougher Sanctions on Iran

What does decertification mean? For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more

Bass, Berry & Sims PLC

OFAC Sanctions: No Entity Too Small or Too Far for Enforcement

Bass, Berry & Sims PLC on

- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran - Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries - Disclosure and cooperation...more

Seyfarth Shaw LLP

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

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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 Volkov Law Group

Sanctions Updates: Iran, Myanmar (Burma) and Cuba

The Volkov Law Group 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

The Volkov Law Group

Learning from Schlumberger’s Mistakes: Doing Business Under Iran General License H

The Volkov Law Group on

Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us for a posting on sanctions compliance. Implementation Day has been hailed as a new stage in Iran-US relations. There has been significant media...more

Faegre Drinker Biddle & Reath LLP

Iran Sanctions Lifted? Implementation Day Creates Compliance Minefield

U.S.-Iranian relations took a major step forward on January 16, 2016, with the arrival of “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA). Although this may present new business opportunities in...more

Goodwin

U.S. Government Licenses Certain Iran-Related Transactions Conducted by Foreign Subsidiaries of U.S. Companies

Goodwin on

On January 16, 2016, the International Atomic Energy Agency verified that Iran had carried out its nuclear commitments under the Joint Comprehensive Plan of Action (“JCPOA”), triggering reciprocal obligations by the United...more

Davis Wright Tremaine LLP

New Iran Sanctions Enactments Apply to U.S. Companies’ Foreign Affiliates and Subsidiaries, and Require SEC Reporting by Public...

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury enforces comprehensive sanctions that regulate, and largely forbid, most forms of trade and financial transactions by U.S. persons with Iran....more

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