News & Analysis as of

Office of Foreign Assets Control ITSR

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

United Medical Instruments Inc. Settles Potential Civil Liability for Alleged Violations of the Iranian Transactions and Sanctions...

by Arnall Golden Gregory LLP on

On February 28, 2017, United Medical Instruments, Inc. (UMI), a California corporation, settled its potential civil liability with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) in the amount of...more

Another Reason To Always Run Compliance Screenings Even If You Are A Non-U.S. Party – OFAC Is Targeting Foreign Companies

by Baker Donelson on

If you are a foreign company that wants access to the U.S. financial markets, make sure you understand the U.S. Iran Transactions and Sanctions Regulations (ITSR). Administered by the U.S. Department of Treasury’s Office of...more

Iran and Russia Sanctions Programs Under a Trump Administration–What to Expect

by Baker Donelson on

In the final weeks of December, President Obama amended sanctions to both the Iran and Russia programs. These changes further relaxed sanctions on Iran while they tightened sanctions on Russia. Yet, just three days from the...more

OFAC Eases Restrictions on Medical and Agricultural Exports to Iran

by Alston & Bird on

On December 23, 2016, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued a final rule amending the Iranian Transactions and Sanctions Regulations (ITSR) to expand the scope of permissible exports and...more

Happy New Year: OFAC Expands Exports of Medical Devices to Iran

by Bass, Berry & Sims PLC on

Effective December 23, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR) to expand the scope of medical devices that can be exported to...more

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

by Dechert LLP on

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….)

by Arnall Golden Gregory LLP on

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

by Michael Volkov on

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

by White & Case LLP on

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

by Kelley Drye & Warren LLP on

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

by Cooley LLP on

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

by White & Case LLP on

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

Iran Sanctions Lifted? Implementation Day Creates Compliance Minefield

by Faegre Baker Daniels on

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

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

by Dentons on

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

by Foley Hoag LLP on

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...

by Dechert LLP on

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

The New Year Brings New Sanctions Against Iran

by King & Spalding on

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

by Morgan Lewis on

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

by Proskauer Rose LLP on

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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