News & Analysis as of

Office of Foreign Assets Control Iran Sanctions

OFAC Pushes Iran Sanctions Enforcement

by Michael Volkov on

Many companies have been laser-focused on anti-corruption compliance, and with good reason given the risks and consequences of an anti-corruption enforcement action. In doing so, companies have to be careful to avoid ignoring...more

A New Trend? Singapore Company Targeted for U.S. Dollar Payments to Iranian Entities

by Jones Day on

The U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC") recently announced a settlement with CSE TransTel Pte. Ltd. ("TransTel"), a wholly owned subsidiary of CSE Global Limited ("CSE Global"), both of...more

US Enacts “Countering America’s Adversaries Through Sanctions Act” Expanding Its Russia, Iran, and North Korea Sanctions Programs

by White & Case LLP on

On August 2, 2017, the President signed into law the "Countering America's Adversaries Through Sanctions Act," providing a number of new sanctions against Russia, Iran, and North Korea. The President also issued a signing...more

OFAC Pushes New Limits on Jurisdiction of U.S. Sanctions by Penalizing Non-U.S. Companies for “Causing” Violations by Making U.S....

On July 27, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the civil settlement with CSE TransTel Pte. Ltd. (“TransTel”) and CSE Global Limited (“CSE Global”) in the amount of...more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

Toughening of sanctions against Russia, Iran and North Korea: Ten key provisions (Russian and English)

by Latham & Watkins LLP on

President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions. On Wednesday, August 2, 2017, President...more

President Trump Signs New Sanctions Legislation into Law

by Jones Day on

On August 2, 2017, President Trump signed the "Countering America's Adversaries Through Sanctions Act" ("Act") into law. The Act, which codifies and strengthens sanctions against Russia and expands sanctions against Iran and...more

New Sanctions Law Complicates Trade Compliance

by Michael Volkov on

Politics and sanctions law go hand-in-hand. In a rare instance of bi-partisanship, Congress united to constrain the administration’s ability to modify the existing sanctions program against Russia. At the same time, Congress...more

New Law Extends U.S. Sanctions Against Russia

by Bass, Berry & Sims PLC on

Over the past month, we have closely monitored efforts by the U.S. Congress to tie the president’s hands over sanctions on Russia. Today, the president signed the Countering America’s Adversaries Through Sanctions Act...more

Red Notice Newsletter - July 2017

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

One Year From Now, You May Be Out of Iran: Trump Administration Policy and the Timeline for Snapback

On July 17, 2017, the U.S. State Department certified that Iran continues to meet the conditions of the Iran nuclear agreement known as the Joint Comprehensive Plan of Action, or JCPOA. As a result, for the next 90 days, the...more

Congress Passes Russia, Iran, and North Korea Sanctions Bill in Sweeping Move

by Reed Smith on

Last week, the U.S. House of Representatives and the Senate voted overwhelmingly to pass the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). President Trump is expected to sign the bill. The legislation...more

Trump Administration Re-Certifies Iranian Compliance with the Joint Comprehensive Plan of Action but Applies New Sanctions to...

by Allen & Overy LLP on

The Trump administration recently re-certified that Iran is in compliance with the Joint Comprehensive Plan of Action (JCPOA, otherwise known as the “Iran Deal”), thereby extending the sanctions relief afforded to Iran...more

New Sanctions Despite Iran’s Compliance With The JCPOA

by Fox Rothschild LLP on

Last week the Trump administration announced new Iran-related sanctions imposed against 18 Iranian entities and individuals. The sanctions are the administration’s response to Iran’s ballistic missile program and...more

U.S. Announces Updates to Iran-Russia Sanctions Bill

by Cozen O'Connor on

On Tuesday, July 18, 2017, the Trump administration announced new sanctions against entities and individuals with ties to Iran. The U.S. Department of State (DOS) and U.S. Department of the Treasury have listed 18 entities...more

Trump Administration Re-Certifies Iranian Compliance with Nuclear Agreement; Imposes Sanctions on Additional Entities for Other...

by Hogan Lovells on

On July 17, the Department of State communicated to Congress that Iran remains in compliance with its obligations under the Joint Comprehensive Plan of Action (JCPOA), the nuclear agreement reached over Iran’s nuclear program...more

Lessons in Civil Forfeiture and Attachment: U.S. May Seize 650 Fifth Avenue

by Ballard Spahr LLP on

On June 29, dual trial verdicts in the Southern District of New York paved the way for the government to seize 650 Fifth Avenue, a 36-story building in Manhattan valued at up to $1 billion (“the Property”). The defendants,...more

Sanctions Round Up: First Half

by Shearman & Sterling LLP on

The first six months of the Trump Administration saw several notable developments for US sanctions, with particular implications for Russia and Iran. The Administration also declared a shift in US policy toward Cuba. ...more

Red Notice Newsletter - June 2017

ANTICORRUPTION DEVELOPMENTS - Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program - On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more

Rare Court Case Sheds Light on U.S. Sanctions Enforcement

by Bass, Berry & Sims PLC on

It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more

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

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