News & Analysis as of

Iran Sanctions Office of Foreign Assets Control

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

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

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

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

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

From Obama to Trump – Sanctions Roundup

by King & Spalding on

The Office of Foreign Assets Control (OFAC) of the U.S. Department of Treasury has issued several significant updates to various sanctions programs over the last several weeks. Beginning during President Barack Obama’s last...more

ZTE Pays the Price for Circumventing Sanctions and Export Controls

by Michael Volkov on

Here is a real zinger – clients sometimes do not tell their lawyers the truth. I will wait a minute while you get off the floor because I know everyone is shocked and amazed that this happens. But in the recent ZTE case,...more

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...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

New Iran Designations: OFAC Adds 25 Persons to the SDN List in Response to Iran’s Ballistic Missile Test

by Allen & Overy LLP on

On February 3, 2017, the U.S. Office of Foreign Assets Control (OFAC) added 25 persons to its List of Specially Designated Nationals and Blocked Persons (the SDN List, and every person thereon, an SDN) as a result of their...more

Trump Administration Takes Moderate Steps Against Iran. What Comes Next?

by Hogan Lovells on

On Friday, February 3, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced it was designating 25 entities and individuals as Specially Designated Nationals (SDNs) for their involvement in...more

Another Reason To Always Run Compliance Screenings Even If You Are A Non-U.S. Party – OFAC Is Targeting Foreign Companies

by Baker Donelson on

If you are a foreign company that wants access to the U.S. financial markets, make sure you understand the U.S. Iran Transactions and Sanctions Regulations (ITSR). Administered by the U.S. Department of Treasury’s Office of...more

Trump Administration Makes First Iran Sanctions Designations

Key Points - - The U.S. Department of the Treasury’s Office of Foreign Assets Control has added 25 new entities and individuals to its Specially Designated Nationals List, including some located in China, Lebanon,...more

Presidential “Notice” Triggers New Iran Sanctions Designations

by King & Spalding on

On February 3, 2017, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury added twenty-five individuals and entities to its Specially Designated Nationals (“SDN”) List. According to the White...more

Red Notice Newsletters - Chinese

ANTICORRUPTION DEVELOPMENTS - Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action – On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more

Trump Administration Turns Up the Heat on Iran

by Cozen O'Connor on

On February 3, 2017, in response to recent Iranian ballistic missile tests, the U.S. Office of Foreign Assets Control (OFAC) added 13 individuals and 12 entities to the Specially Designated Nationals and Blocked Persons (SDN)...more

Trump Administration Sanctions Iran in Response to Missile Test

by Holland & Knight LLP on

The Trump Administration responded on Feb. 3, 2017, to Iran's latest series of ballistic missile tests by sanctioning certain individuals and companies involved in Iran's efforts to procure ballistic missile technology or...more

Treasury Department Imposes New Sanctions Against Iran and Clarifies Russia Cyber Sanctions

by WilmerHale on

New Iran Designations - On Friday, the US Treasury Department's Office of Foreign Assets Control (OFAC) designated 25 individuals and entities under Executive Orders 13382 and 13224 for their roles in procuring...more

U.S. Designates New Individuals and Entities for Iran-Related Sanctions

by Reed Smith on

Today, the U.S. Treasury Department, Office of Foreign Assets Control (“OFAC”) imposed sanctions on an additional 13 individuals and 12 entities identified by the Treasury Department as “entities and individuals involved in...more

Sanctions Round Up: Fourth Quarter 2016 and President Donald J. Trump

by Shearman & Sterling LLP on

On November 8, 2016, Donald John Trump was elected the 45th President of the United States. Following fiery criticism of the Obama Administration’s sanctions policies, including the Iran deal, the lifting of substantial parts...more

Red Notice Newsletter - January 2017

ANTICORRUPTION DEVELOPMENTS - Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action – On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more

Business Litigation Report - January 2017

China's 2016 Cybersecurity Law Will Change the Way Multinational Companies Do Business in China - China adopted its controversial Cybersecurity Law on November 7, 2016. The law, which will take effect on June 1, 2017,...more

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