ITSR

News & Analysis as of

October 2016: U.S. Claims Ability to Prosecute Foreign Actors Acting Abroad for Violating U.S. Sanctions Laws

On March 19, 2016, FBI agents arrested Turkish citizen and resident Reza Zarrab at Miami International Airport, soon after he landed with his wife and young child to visit Disney World. The principal charge, brought by the...more

District Court Upholds Indictment of Turkish/Iranian Billionaire Charged with Evading US Economic Sanctions against Iran

U.S. District Court Judge Richard M. Berman denied a motion to dismiss the indictment in the closely followed criminal prosecution of Reza Zarrab, a Turkish/Iranian businessman charged with conspiring to evade U.S. economic...more

Every U.S. Life Sciences Company Needs an Export Control Compliance Program (No, Really….)

Two recent settlements by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) confirm that every U.S. life sciences company engaging in exports should have an effective U.S. export control compliance...more

OFAC General License Loosens Restrictions on Non-US Carrier Flights to Iran

On Friday, July 29, the US Office of Foreign Assets Control (OFAC) issued General License J under the Iranian Transactions and Sanctions Regulations (ITSR). This general license authorizes non-US airlines to fly US origin...more

Sanctions Updates: Iran, Myanmar (Burma) and Cuba

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

US Issues Additional Guidance Regarding Iran Sanctions Relief

On June 8, 2016, the US further clarified the scope of the sanctions relief provided to Iran as of January 16, 2016 (known as "Implementation Day") under the Joint Comprehensive Plan of Action (JCPOA). The Department of the...more

OFAC General License Facilitates Negotiations With Iran for Commercial Passenger Aircraft

Since we last spoke of "Implementation Day" established on January 16 under the Joint Comprehensive Plan of Action (see "Implementation Day" Brings Openings for Commercial Aircraft Sales With Iran advisory from January 22),...more

Epsilon Case Highlights the Need for Sanctions Due Diligence on Resellers

As global companies begin to reenter the Iranian market, a decision issued by the U.S. District Court for the District of Columbia is an important reminder that resellers and distributors can generate liability for U.S....more

Alert: Cuban and Iranian Embargoes Lifted? Not so Fast…Restrictions Remain on Certain Academic and Research Activities

Much has been written recently about the lifting of the US embargoes targeting Iran and Cuba. Despite recent liberalization in discrete areas (e.g., travel, family remittances, and internet based communications),...more

Overview of US and EU “Implementation Day” Guidelines on Iran Sanctions Relief

This overview describes the status of US and EU sanctions following the first round of nuclear-related sanctions relief that occurred on “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA) concluded with...more

Some Sanctions Relief for Iran, But Mostly Status Quo for the U.S. Auto Industry

On January 16, 2016, the International Atomic Energy Agency (IAEA) declared that Iran had implemented its commitments to ensure that its nuclear program will be limited to peaceful purposes. With that, the United States...more

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

U.S. Lifts Some Iran Sanctions, But Robust Restrictions Remain

U.S. trade relations with Iran took a significant turn on Saturday, January 16, 2016, with the dawning of Implementation Day under the Joint Comprehensive Plan of Action ("JCPOA"), in furtherance of which the U.S. took, or is...more

US expands list of medical items authorized for export or re-export under Iran general license

On November 2, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated and expanded the list of “medical supplies” that can qualify for export or re-export to Iran under the existing...more

OFAC Expands List of Medical Supplies Eligible for Export to Iran under General License

On November 2, 2015, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the List of Medical Supplies eligible for export or reexport to Iran under the general license set forth at Section...more

Opportunity, Uncertainty for Entities Wishing to Do Business with Iran

Nuclear Deal with Iran Holds Out Possibility of Phased Relaxation of Sanctions - On July 14, 2015, the United States and five other countries (collectively known as the P5+11) reached a Joint Comprehensive Plan of...more

Two Non-U.S. Banks Agree to Pay Penalties Totaling $160 Million for Violations of U.S. Sanctions Laws Resulting from Omnibus...

Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more

REGULATORY: International Trade: U.S. Continues to Expand Sanctions Against Iran by Christine Savage, Jane Cohen and Shannon Doyle...

Preventing Iran from obtaining nuclear weapons capability remains one of the United States’ preeminent national security objectives,. Thus, the United States and its allies have increasingly turned to economic sanctions as a...more

The New Year Brings New Sanctions Against Iran

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

New OFAC Regulations Implement Iranian Sanctions

Grace period through March 8 provided to foreign subsidiaries to wind down Iranian transactions. On December 26, 2012, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Iranian...more

Final Rule on New Iranian Sanctions Published

On December 26, 2012 the Department of the Treasury's Office of Foreign Assets Control ("OFAC") published a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (the "ITSR"), to implement...more

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