News & Analysis as of

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

OFAC Issues Finding of Violation to a Bank for Violations of Iranian Transactions and Sanctions Regulations

On October 21, OFAC issued a Finding of Violation to a Chicago-based bank as the successor of a bank that processed six funds transfers totaling approximately $67,000. According to OFAC, the predecessor bank, between February...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

Negotiators Have Reached Deal with Iran – U.S. Persons Should Not Expect Quick Relief From Sanctions

On July 14, 2015, the five permanent members of the UN Security Council (China, France, Russia, the United Kingdom, and the United States) plus Germany (the “P5 + 1”) announced a Joint Comprehensive Plan of Action (JCPOA)...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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