News & Analysis as of

Office of Foreign Assets Control (OFAC) ITSR Iran

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – September 2023 Update

Bass, Berry & Sims PLC on

September saw a number of enforcement actions involving Iran. First, the Office of Foreign Assets Control (OFAC) announced separate settlements with 3M and Emigrant Bank for violations of the Iranian Transactions and...more

BCLP

SAP Enforcement Action Underscores Importance of Ensuring Compliance Programs Address Considerations Associated with Business...

BCLP on

On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more

Kelley Drye & Warren LLP

U.S. Expands Sanctions on the Iranian Financial Sector

Kelley Drye & Warren LLP on

Last week, the United States expanded sanctions on Iran’s financial sector by designating 18 major Iranian banks as Specially Designated Nationals (SDNs) and authorizing additional future sanctions on the Iranian financial...more

Hogan Lovells

U.S. government ends uncertainty surrounding the use of the Central Bank of Iran (CBI) in humanitarian trade with Iran and opens...

Hogan Lovells on

On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under...more

The Volkov Law Group

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

The Volkov Law Group on

On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”).  (Available here).  Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Terminates All Remaining Sanctions Relief Under Iran Nuclear Deal

On November 5, 2018, the United States reimposed all remaining nuclear-related sanctions against Iran that it had previously lifted in connection with its implementation of the Joint Comprehensive Plan of Action (JCPOA) in...more

Hogan Lovells

Re-imposing sanctions on Iran, Trump discards nuclear deal

Hogan Lovells on

On 5 November 2018 the United States re-imposed the remaining nuclear-related secondary sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) against Iran that previously had...more

Hogan Lovells

Iran sanctions: Snapback becomes reality

Hogan Lovells on

The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more

Hogan Lovells

U.S. stays the course on re-imposing Iran sanctions

Hogan Lovells on

In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more

Dechert LLP

The United States Tightens Iran Sanctions by Revoking Authorizations

Dechert LLP on

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has tightened Iran sanctions. Specifically, OFAC revoked authorizations that (1) allowed foreign subsidiaries of U.S. companies to do business in Iran;...more

Kelley Drye & Warren LLP

OFAC Formally Rescinds General License H – Foreign Subsidiaries of U.S. Companies Must Withdraw from Iran

Yesterday the Office of Foreign Assets Control (OFAC) formally rescinded General License H, requiring foreign subsidiaries of U.S. companies to wind down remaining business related to Iran by 11:59 pm EST on November 4, 2018....more

BCLP

US Reimposes Nuclear Sanctions against Iran (IRB No. 575)

BCLP on

On May 8, 2018, President Trump announced that the United States is pulling out of the Joint Comprehensive Plan of Action (“JCPOA”). The announcement will result in the reimposition of the sanctions that were lifted or waived...more

Baker Donelson

Iran Sanctions Update: No Change for Companies as Pressure Shifts Back to President Trump as Key Deadline Passes

Baker Donelson on

On December 12, a key deadline passed for Congress to reimpose nuclear-related sanctions against Tehran, shifting the pressure back to the executive branch and setting new deadlines that will be critical to the fate of the...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Puts Companies on Notice: Due Diligence in Iran Can Trigger Sanctions Violations

• This enforcement action highlights the heightened sanctions compliance and enforcement risk that companies face when engaging third-party consultants to perform due diligence on counterparties. U.S. persons must make clear...more

Fox Rothschild LLP

OFAC Settles Iran Sanctions Claims

Fox Rothschild LLP on

On Thursday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $415,350 settlement agreement with COSL Singapore Ltd. (“COSL”). The parties settled a potential civil liability claim...more

Baker Donelson

OFAC’s Broad Latitude To Impose Iran Sanctions Affirmed by D.C. Circuit

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

Perkins Coie

Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

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

Alston & Bird

OFAC Eases Restrictions on Medical and Agricultural Exports to Iran

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

Bass, Berry & Sims PLC

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

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

Kelley Drye & Warren LLP

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

Cooley LLP

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

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

Foley Hoag LLP

Opportunity, Uncertainty for Entities Wishing to Do Business with Iran

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

Dechert LLP

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

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

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