News & Analysis as of

Treasury Department Announces $21 Million Resolution Of Alleged Iran and Sudan Sanctions Violations

On June 5, the Treasury Department’s Office of Foreign Assets Controls (OFAC) announced a Dutch aerospace firm has agreed to pay $21 million to resolve allegations that the company violated U.S. sanctions on Iran and Sudan....more

Red Notice Newsleter

Welcome to the May 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month, on the anticorruption front, Avon Products, Inc. (“Avon”) agrees to pay USD $135 million to settle a...more

Real OFAC Policy Changes Toward Iran—OFAC will consider non Ag/Med exports

As a new round of nuclear talks involving American, European, and Iranian leaders commence this week in Vienna it appears that the first-step deal agreed upon in January has already led to significant changes in OFAC’ s...more

Governance & Securities Law Focus: Europe Edition, April 2014

In this issue: - EU Developments - German Developments - UK Developments - Us Developments - Excerpt from EU Developments - European Commission Proposes to Introduce Shareholder "Say...more

Sanctions Round-Up: First Quarter 2014

In this edition: - Implementation of the Joint Plan of Action with Iran - Additional US Iran-Related Sanctions and Licenses - OFAC Civil Settlements - US and EU Sanctions in Response to the Situation in...more

Red Notice Newsletter - March 2014

This month on the anticorruption front, a New York court orders two former Siemens executives to pay record civil penalties in a bribery case involving the company’s Argentina business; Canada prosecutes former executives...more

OFAC Expands and Clarifies License for Exports of Personal Communications Items and Services to Iran

The Department of the Treasury, Office of Foreign Assets Control (OFAC), amended the Iran personal communications General License D-1 (GL D-1) on Feb. 7, 2014, expanding, clarifying and superseding the May 2013 General...more

OFAC Publishes New Guidance On Temporary And Limited U.S. Sanctions Relief For Iran

On January 30, 2014, the Office of Foreign Assets Control (OFAC) published in the Federal Register Guidance Relating to the Provision of Certain Temporary Sanctions Relief in Order to Implement the Joint Plan of Action...more

Capital Thinking: International

Executive and Legislative Branch Activity - Iran - On February 6, Treasury’s Office of Foreign Assets Control introduced the Foreign Sanctions Evaders List (FSE List) to identify foreign persons sanctioned under...more

Temporary Iran Sanctions Relief

Relief is very limited and alleviates threat of sanctions regarding transactions by non-U.S. or foreign persons. On January 30, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published...more

Temporary Suspension of Limited US Sanctions Restrictions on Dealings With Iran

On January 20, 2014, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued Guidance Relating to the Provision of Certain Temporary Sanctions Relief (Guidance) to explain the limited and temporary...more

OFAC Announces Sanctions Settlement With Securities Intermediary

On January 23, the Treasury Department’s OFAC announced that a Luxembourg bank agreed to pay $152 million to resolve potential civil claims that the bank concealed the interest of the Central Bank of Iran (CBI) in certain...more

United States Implements Temporary Changes to Iran Sanctions under Interim Agreement

On January 20, 2014, the U.S. Treasury and State Departments took steps to implement temporary and limited changes to U.S. sanctions policy for Iran as agreed under the interim nuclear deal reached by Iran and the P5 + 1...more

OFAC Publishes Key Guidance Related to the Lifting of Certain Sanctions on Iran

As part of the implementation of the initial understanding with Iran, pursuant to the Joint Plan of Action among the United States and certain of its trading partners ("the Agreement") regarding the rollback of Iran's nuclear...more

Sanctions Round-Up: Fourth Quarter 2013

As 2013 drew to a close, a potentially groundbreaking agreement was reached with Iran regarding its nuclear program, leading to much speculation about how certain sanctions might be suspended, and under what conditions. While...more

How Should U.S. Companies React To The Iran Nuclear Deal And Which Sanctions Are Suspended?

The United States agreed to suspend certain sanctions against Iran over the weekend as part of an agreement to curb the Iranian nuclear program. The agreement, which provides for a six-month first step towards a...more

Iran Notices Update: SEC-Registered Issuers Continue to Adapt to Their New Normal

It has been over eight months since SEC-registered issuers began making mandatory disclosures of business activities in or with Iran. During that period, issuers have filed over 400 Iran Notices with the SEC, including...more

Treasury Fines Foreign Investment Firm Over Iran Sanctions Violations

On October 21, the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a $1.5 million civil penalty in an enforcement action against a UAE-based investment and advising company for violating the Iranian...more

Politics and Consequences: An Update on U.S. Sanctions Against Iran

Since Hassan Rouhani’s election to the Iranian presidency, some U.S. leaders have expressed interest in diplomatic talks with Iran. It is currently unclear whether any such talks will ever occur, or on what terms. In the...more

Red Notice Newsletter - September 2013

INTRODUCTION - Welcome to the September 2013 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, several U.S. financial executives plead guilty in a...more

OFAC Issues Two General Licenses Affecting Iranian Transactions and Sanctions Regulations

On September 10, 2013, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued two General Licenses affecting the Iranian transactions and sanctions regulations. General License E authorizes...more

OFAC Expands General License for Export of Basic Medical Supplies to Iran; Provides Additional Guidance

On July 25, 2013, the Office of Foreign Asset Control (“OFAC”) announced the significant expansion of its List of Basic Medical Supplies (“LBMS”). Simultaneously, OFAC issued clarifying Guidance on the Sale of Food,...more

Sanctions Round-Up: Second Quarter 2013

In this issue: - The Iran Freedom and Counter-Proliferation Act of 2012 - E.O. 13645, issued June 3, 2013 - Enforcement Against Foreign Sanctions Evaders - Enforcement Against Human Rights...more

Understanding OFAC’s Newest General License Regarding Personal Communication Services in Iran

The Office of Foreign Assets Control (OFAC) recently released General License D regarding the exportation of certain services, software and hardware pertaining to personal communication exchange in Iran....more

Executive Order Targets New Sectors of Iranian Economy for Sanctions: Are You Prepared to Comply?

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

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