News & Analysis as of

Office of Foreign Assets Control (OFAC) Joint Comprehensive Plan of Action (JCPOA)

Morrison & Foerster LLP

EU Sanctions Year in Review 2023

In 2023, the European Union continued to use economic sanctions as one of its foreign policy tools, and not only in response to Russia’s war in Ukraine. New sanctions and adjustments to existing regimes reflect the EU’s...more

K2 Integrity

2023 in Review: An Eventful Year in Sanctions and Enforcement

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The sanctions world experienced another action-packed year in 2023. Sanctions against Russia dominated the year in terms of the number of designations and new restrictions, and the attacks perpetrated by Hamas in Israel on 7...more

The Volkov Law Group

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

The Volkov Law Group on

The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more

The Volkov Law Group

Murad Pays OFAC $3.3 Million for Iran Sanctions Violations; Former Senior Executive Pays $175k

The Volkov Law Group on

Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million.  Murad was acquired by Unilever United...more

Husch Blackwell LLP

International Trade Law: 2022 Year in Review & Outlook for 2023

Husch Blackwell LLP on

We are pleased to announce that our team’s fourth-annual international trade law year-in-review report was published just before the New Year. In it, we take a detailed look at how 2022 played out and explore how 2023 might...more

K2 Integrity

The Iranian Women’s Movement: Sanctions, Human Rights, and the Targeting of Iran’s Morality Police

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Current Situation in Iran - A historic and powerful popular movement—led by women in response to the murder of Mahsa Amini while in the custody of the Iranian Morality Police in mid-September—is currently unfolding in...more

Foley Hoag LLP - White Collar Law &...

Review of Sanctions and Export Control Developments in 2021 and What to Expect in 2022

This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more

WilmerHale

Top EU Court rules on the EU Blocking Regulation against U.S. sanctions for the first time

WilmerHale on

Top EU Court Rules on the EU Blocking Regulation Against US Sanctions for the First Time - On December 21, 2021, the Court of Justice of the European Union (CJEU), sitting as a “Grand Chamber” (a formation used, among...more

Morrison & Foerster LLP

Sanctions Legislation Watch: What to Expect from Congress as 2021 Comes to a Close

As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more

Sheppard Mullin Richter & Hampton LLP

The EU – U.S. Sanctions Dilemma: The Advocate General of the European Court of Justice Weighs in

In May 2018 the United States announced the reinstitution of sanctions against Iran that had previously been lifted pursuant to the Joint Comprehensive Plan Action (“JCPOA”). The U.S. sanctions on Iran that were revived...more

Sheppard Mullin Richter & Hampton LLP

JCPO-Wait-A-Minute: How New Talks Between the U.S. and Iran Could Revive the Iran Nuclear Deal

Since President Biden took office and put his national security team in place, we have wondered about the future of the Iran Nuclear Deal. In the past weeks, the Biden Administration has taken formal steps to possibly restore...more

Morrison & Foerster LLP

Top 10 Lessons Learned From OFAC's 2019 Financial Institution Enforcement Actions (OFAC 2019 Year In Review Part 2)

As we mentioned in the first part of our U.S. Sanctions Year in Review series, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) had an extraordinarily busy year in 2019, and its enforcement activity...more

Jones Day

New Sanctions Target Additional Sectors of Iranian Economy

Jones Day on

The Situation: The Trump administration announced a new round of sanctions on January 10, 2020, following escalating tensions between the United States and Iran. The Result: The new sanctions complement existing sanctions...more

Husch Blackwell LLP

Trump Administration Expands Iran Sanctions To New Sectors In Recent Executive Order

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In a January 14th Executive Order, President Trump expanded sanctions on Iran after a ballistic missile attack on two American military bases in Iraq. Executive Order 13902 expands secondary sanctions on Iran to capture...more

Orrick, Herrington & Sutcliffe LLP

U.S. Targets Additional Iranian Sectors for Sanctions: Broadly Increasing Exposure for Non-U.S. Companies

With new Iran-related sanctions, the U.S. government is making good on threats to give third-country companies a choice – participate in the U.S. market or participate in the Iranian market. ...more

Morrison & Foerster LLP

The United States Imposes Additional Secondary Sanctions on Iran as Geopolitical Tensions Flare

With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more

White & Case LLP

Iran Threatens Partial JCPOA Suspension; US Imposes Sanctions on Certain Iranian Metals Sectors

White & Case LLP on

On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more

BCLP

A Delicate Balance

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How should we approach competing sanctions risks? Among the numerous regulatory compliance risks faced by financial institutions, economic and trade sanctions risks commonly receive a great deal of attention....more

Williams Mullen

U.S. Sanctions Laws: Dangers Ahead For Foreign Companies (Part II)

Williams Mullen on

The following is Part II of this article. Secondary Sanctions – Requirements On Non-U.S. Parties That Have No Contacts With the U.S. OFAC also has adopted sanctions that specifically apply to non-U.S. companies and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2019 Insights: Key Developments in US Sanctions

In 2018, the United States continued to expand its sanctions programs and increase enforcement. While President Donald Trump’s decision to re-impose nuclear-related sanctions on Iran has perhaps drawn the most attention, key...more

A&O Shearman

Sanctions Round Up: Fourth Quarter 2018

A&O Shearman on

Closing out 2018, OFAC announced its plan to lift sanctions against United Co. Rusal and others, despite bi-partisan opposition from Congress. Simultaneously, OFAC continued to target Russia’s defense and intelligence sectors...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

BCLP

Trade Policy Tensions Emerge As U.S. Reimposes Sanctions Against Iran (IRB No. 577)

BCLP on

Pursuant to the President’s May 8, 2018, memorandum announcing the United States’ withdrawal from the Joint Comprehensive Plan of Action (JCPOA), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)...more

The Volkov Law Group

OFAC Completes Re-Imposition of Iran Sanctions

The Volkov Law Group on

On November 5, 2018 the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) completed the process to re-impose the Iran sanctions program. The 180-day wind-down period for termination of the United States’...more

Akin Gump Strauss Hauer & Feld LLP

Iran Sanctions Are Here—Breaking Down What This Means For Business

• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more

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