Corporate Law Report: Managing Cyber Risks, BYOD, Obama's NLRB Crisis, Iran Sanctions, and More
Effective July 1, 2013, President Obama's Executive Order 13645 implements certain provisions of the Iran Freedom and Counter-Proliferation Act of 20121 (IFCA) and expands the Iranian sanctions regime to new sectors of Iran’s...more
Introduction - US sanctions restrictions have traditionally exempted exchanges of information and informational materials. However, because the prohibitions on exports of software and services are sufficiently broad to...more
Most significantly, on June 3, 2013, President Obama issued Executive Order 13645 (78 Fed. Reg. 33945) that, effective July 1, 2013, implements provisions of the Iran Freedom and Counter-Proliferation Act of 2012 and imposes...more
On May 30, 2013, the Office of Foreign Assets Control (“OFAC”) of the United States Department of the Treasury announced the issuance of a general license authorizing the exportation to Iran of certain services, software, and...more
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
In this issue: - OFAC Releases New SDN Search Tool - Additional Provisions Targeting Iran Go Into Effect - OFAC Continues to Target Foreign Sanctions Evaders - Section 219 Disclosures Begin - Burma...more
On February 6, 2013, the Office of Foreign Assets Control (OFAC) published two guidance documents related to the Iranian sanctions regulations and licenses. The first is Guidance on Humanitarian Assistance and Related...more
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
As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing. As we reported in October and November, Washington’s commitment to denying Iran the ability to advance...more
A number of companies have filed IRANNOTICEs on EDGAR with the SEC (thanks to Broc Romanek for pointing this out). The notices reference disclosures made in annual reports pursuant to Section 219 of the Iran Threat Reduction...more
Recently, Standard Chartered Bank (SCB) was in the news again for stripping original wire details so that payments would go undetected by the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC)....more
As 2013 begins, the United States has reiterated its commitment to countering the threat posed by Iran by passing new legislation, issuing new regulations and guidance, and bringing into effect new requirements to increase...more
On January 10, the Office of Foreign Assets Control (OFAC) issued an advisory to highlight practices being used to evade sanctions on Iran, including the use of third-country exchange houses or trading companies that are...more
In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - E-COMMERCE - PRIVACY/DATA SECURITY - PAYMENTS -...more
The United States continues to impose additional layers of sanctions on Iran. The rate of change and complexity of U.S. sanctions laws present challenges, particularly where these sanctions have extraterritorial effect on the...more
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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