News & Analysis as of

Iran: limited sanctions relief extended to 24 November 2014

January 2014, both the EU and U.S. brought into force measures which temporarily suspended and relaxed (for a period of six months, to end on 20 July 2014) some of the sanctions in place against Iran. This reflected the Joint...more

Real OFAC Policy Changes Toward Iran—OFAC will consider non Ag/Med exports

As a new round of nuclear talks involving American, European, and Iranian leaders commence this week in Vienna it appears that the first-step deal agreed upon in January has already led to significant changes in OFAC’ s...more

OFAC Expands and Clarifies License for Exports of Personal Communications Items and Services to Iran

The Department of the Treasury, Office of Foreign Assets Control (OFAC), amended the Iran personal communications General License D-1 (GL D-1) on Feb. 7, 2014, expanding, clarifying and superseding the May 2013 General...more

Iran sanctions relief: what does it mean for businesses in the Middle East?

On January 20, 2014, the U.S. Department of the Treasury and U.S. Department of State issued guidance implementing the Joint Plan of Action (“JPOA”) entered into by the United States, the United Kingdom, France, Russia, the...more

OFAC Publishes New Guidance On Temporary And Limited U.S. Sanctions Relief For Iran

On January 30, 2014, the Office of Foreign Assets Control (OFAC) published in the Federal Register Guidance Relating to the Provision of Certain Temporary Sanctions Relief in Order to Implement the Joint Plan of Action...more

Capital Thinking: International

Iran - In his State of the Union address last Tuesday before a joint session of Congress, President Obama acknowledged Congressional sanctions contributed to bringing about the P5+1 interim agreement with Iran. ...more

Implementation of Temporary Iran Sanctions Relief

Last November, the group of nations known as the P5+1 (United States, U.K., Germany, France, Russia and China) reached an initial understanding with Iran whereby Iran agreed to accept limits on its nuclear program in exchange...more

Iran Sanctions Relief Offers Limited Opportunities and Substantial Risks

Introduction and Summary - On January 20, 2014, the departments of State and the Treasury announced details of the United States’ plan to suspend certain sanctions against Iran pursuant to the November 24, 2013 Joint...more

Iranian Sanctions – Joint Action Plan is Implemented in EU

Background - Implementation of the Joint Action Plan agreed between the E3/EU+3 in October 2013 by suspending certain sanctions against Iran in relation to nuclear proliferation began on 20 January 2014. This...more

Iran Sanctions—Implementation of P5+1/Iran Nuclear Non-Proliferation Agreement

The United States and the European Union have begun relieving Iran of some limited sanctions in exchange for Iran’s curtailing its nuclear proliferation activities....more

United States Implements Temporary Changes to Iran Sanctions under Interim Agreement

On January 20, 2014, the U.S. Treasury and State Departments took steps to implement temporary and limited changes to U.S. sanctions policy for Iran as agreed under the interim nuclear deal reached by Iran and the P5 + 1...more

EU partially suspends Iran sanctions under nuclear deal

I. Introduction - On 20 January 2014, the Council of the European Union (EU) agreed to temporarily suspend certain sanctions against Iran, namely those relating to (re)insurance and transport services for Iranian crude...more

The Sanctions Divide: The White House Pushes to Ease Trade Restrictions on Iran While Congress Contemplates a New Round of...

On November 24, 2013 in Geneva, the five members of the UN Security Council – United States, United Kingdom, France, China, and Russia, plus Germany ("P5+1"), agreed on a Joint Plan of Action ("JPA") to lift some of the...more

Capital Thinking: International

Executive and Legislative Branch Activity - Budget and the Debt Ceiling Debate - With no congressional consensus on a bill to fund the U.S. federal government for FY 2014, on Tuesday, October 1, the U.S....more

Politics and Consequences: An Update on U.S. Sanctions Against Iran

Since Hassan Rouhani’s election to the Iranian presidency, some U.S. leaders have expressed interest in diplomatic talks with Iran. It is currently unclear whether any such talks will ever occur, or on what terms. In the...more

The European Court of Justice Overturns, Unfreezes EU Iran Sanctions

In a series of recent rulings, the European Court of Justice overturned economic sanctions issued by the Council of the European Union (EU) on several Iranian banks and shipping lines. On September 6 and 16, 2013, the Court...more

Sanctions Round-Up: Third Quarter 2013

In this edition: - Iranian Sanctions Eased to Allow Additional Humanitarian Exports and Activities - New Iranian Sanctions Designations Announced - Significant Reduction Waivers Extended - Global...more

EU Court Strikes Down Iran Asset Freeze Sanctions: Council of the European Union Urged to Act with more Rigour

In September 2013, the EU General Court annulled a series of asset freeze sanctions imposed by the Council of the European Union on a number of Iranian entities and one person. The General Court requires the EU regulators to...more

Capital Thinking: International

Executive and Legislative Branch Activity - Syria - Interrupting the congressional recess one week early and after two days of debate, last Wednesday, September 4, the Senate Foreign Relations Committee passed...more

Why China’s Growing Appetite For Iraqi Oil Is Good For America, And The World

For the mass media chorus, postwar Iraq has come to resemble an emblem of American failure. Spurts of violence seem to be embedded into the fabric of everyday life, plaguing the country with disturbing regularity. ...more

Expanded U.S. Sanctions on Iran Effective July 1, 2013

President Obama has issued a new Executive Order that goes into effect July 1, 2013. The Executive Order targets new areas of the Iranian economy for sanctions, including exchange transactions involving Iranian Rials and...more

US Extraterritorial Sanctions Targeting Non-US Insurers for Iran-Related Activities

The US government has again expanded the scope of its Iranian extraterritorial sanctions program with the enactment of the Iran Freedom and Counter-Proliferation Act of 2012 (the “IFCPA”). Among other things, the IFCPA...more

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