Iran

News & Analysis as of

The Table Flip: Trump, the Iran Nuclear Deal, and American Business

- A President Trump will have authority to reinstate sanctions lifted by the Iran Nuclear Deal as well as revoke certain authorizations provided for business with Iran. - Several economic and geopolitical factors may...more

Preparing for the 2017 Public Company Reporting Season

Reevaluate Non-GAAP Disclosures in Light of Updated C&DIs and Other SEC Actions. As the reporting season gets underway, reviewing non-GAAP disclosure practices should remain a top priority in light of the new and updated...more

Forecasting the Trump Administration's First 100 Days

With the 2016 election in the rearview mirror, manufacturers must be mindful of the early initiatives you can expect from Congress and the new administration. With a return to one-party rule, the coming congressional term is...more

Still Serious About Sanctions: OFAC Settles Violations Involving Cuba and Iran

Lest U.S. companies think that Cuba and Iran are entirely open for business, a U.S. government settlement announced earlier this month with National Oilwell Varco, Inc. (NOV), a U.S. oilfield services company, will serve as a...more

Post-Election Sanctions Hangover

With the results in from the U.S. presidential election, companies should begin to consider the potential impact of a Trump presidency on their international business. U.S. economic sanctions were among the hot-button issues...more

Trade Compliance Issues in the New Administration, Part I: Export/Sanctions Laws

A change in administration will likely bring changes in export/sanctions laws and compliance obligations. This will include both last minute amendments by the outgoing administration and initiatives by the new President....more

"Looking Ahead: The U.S. Legal and Regulatory Environment Under a Trump Administration"

Election Day brought an end to a long period of uncertainty that caused market fluctuations and delayed business planning decisions. As we navigate the post-election landscape, many questions remain regarding the potential...more

Sanctions Update: Burma, Cuba, and Iran

Over the past month, substantial changes were made to several sanctions programs affecting Burma, Cuba, and Iran by President Obama and the Department of Treasury Office of Foreign Assets Control (OFAC)....more

Post-Election Outlook: A New, Unpredictable World

In a shock to investors and political analysts around the world, Donald J. Trump won the 2016 Presidential election, putting the Republican Party in charge of the White House and Congress for the first time in a decade. Even...more

Sanctions in Energy: Russia and Iran

US and EU sanctions related to Russia and Iran have a direct and targeted impact on the energy sector. The sanctions regimes against Russia and Iran differ substantially and seem to be moving in different directions. In this...more

Ramifications of US Election for International Sanctions

Yesterday’s election has significant implications for international sanctions, particularly with respect to Iran, Cuba, and Russia. Although we do not want to be unduly alarmist, President-elect Trump’s statements on the...more

Iran on Your Mind? The FAR Should Be, Too.

Over the past year, the big news for companies doing or considering business in Iran has been the scaling back of U.S. and EU economic sanctions. Many global businesses are now permitted to operate in this once prohibited...more

Iran Issues Pre-qualification for Upstream Tenders

Iran is said to be targeting an increase in oil production from 3.85 to 4 million barrels per day by the end of 2016. Iran is also hoping to start export of a new heavy oil, called West Karun, and which is expected to compete...more

OFAC Provides Further Guidance On Iranian Sanctions

This month the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) updated its ‘Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA)...more

Those Three Little Words: OFAC’s Subtle Language Shift Could Create Sweeping Change on Iran Investment

Article Highlights: - Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks. - Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United...more

Treasury Department Issues Guidance Intended to Ease Dollar-Denominated Foreign Transactions with Iran

The United States Treasury Department’s Office of Foreign Asset Control (OFAC) amended its guidance on Iranian sanctions to clarify that some transactions with Iran by non-U.S. institutions are permitted, provided that such...more

From Implementation to Takeoff: Nine Months Later, OFAC Issues Licenses to Boeing and Airbus for Commercial Aircraft Deals With...

The beginning of the year brought the arrival of “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA) and its potential for business opportunities in Iran that had been shut off for decades (See Jan. 22,...more

“Reason To Know” – A Chilling Term For Exporters

It’s a simple question – if a U.S. exporter sells its product to a foreign customer, and the customer resells the product to a prohibited country such as Iran, can the U.S. exporter have liability for an export violation? ...more

Considerations for Travel to Iran to Explore Relaxed Trade Opportunities

Before booking your airfare, be mindful of these potential issues. In light of liberalized trade with Iran made possible by the Office of Foreign Assets Control’s (OFAC’s) General License H and the relaxation of US...more

Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New “General License J” authorizes many Boeing, Airbus, and...more

From Altamont to Airbus

What was one of the most tragic events in the history of rock and roll? High up on the list must rank the Altamont concert, held at Altamont Race Track on December 6, 1969. It was so bad that many people felt the 60s actually...more

August 2016 Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions

This edition of the Cozen O’Connor Aviation Regulatory Update discusses new FAA reauthorization legislation, DOT awards for U.S. carrier scheduled service to Cuba, DOT’s decision to address consumer notification requirements...more

New License Authorizing U.S. Aircraft to Make Temporary Sojourns to Iran Marks Further Lifting of Secondary Sanctions

Further weakening secondary sanctions, the Department of Treasury’s Office of Foreign Assets Control has issued a new license to allow non-U.S. persons to fly some U.S. aircraft to Iran for temporary sojourn. While General...more

Six Months After Implementation of Iran Nuclear Agreement: Top 10 Observations

Various factors continue to shape and limit trade and investment between Iran and the rest of the world. Six months have passed since the implementation of the nuclear agreement with Iran, officially known as the Joint...more

German Employee's Dismissal at U.S. Regulator's Behest Ruled Invalid

On July 13, 2016, the Frankfurt Higher Labor Court held the dismissal of an employee in response to demands by the New York State Department of Financial Services (NYDFS) was invalid. (Frankfurt Labor Court, 18 Sa 1498/15)....more

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