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

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

Iran Speech Shifts Pressure to Congress, But Changes Little for U.S. Businesses

President Trump’s October 13 speech denounced Iran’s “fanatical regime” as a “menace,” and threatened to terminate the 2015 Iran nuclear deal negotiated by Barack Obama and formally known as the Joint Comprehensive Plan of...more

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

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

6/19/2017  /  Exports , Iran , Iran Sanctions , ITSR , OFAC

Update on Regulatory Compliance in the Global Health Care Industry

A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

New License Authorizing U.S. Aircraft to Make Temporary Sojourns to Iran Marks Further Lifting of Secondary Sanctions

Further weakening secondary sanctions, the Department of Treasury’s Office of Foreign Assets Control has issued a new license to allow non-U.S. persons to fly some U.S. aircraft to Iran for temporary sojourn. While General...more

Is Iran Open for Business for U.S. Exporters?

On August 7, 2015, the U.S. Government issued a revised Guidance regarding Iran and also issued a Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry. The bottom...more

Iran – Don’t Forget the General License!

Iran entered into a historic nuclear agreement with the U.S. and other world powers on July 14th 2015. The agreement will allow the licensing of the export, re-export, sale, lease or transfer to Iran of commercial passenger...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

BVI Company In Trouble Over Plans to Ship Engines to Iran

We usually don’t post enforcement summaries. However, I wanted to insure everyone was aware that the United States government is really going after non-U.S. entities. Please see below. Note it is the Commerce Department not...more

What can you take-away from Total S.A.’s recent FCPA settlement?

I try to avoid talking about Foreign Corrupt Practices Act (FCPA) issues seeing as though it’s quite a popular topic. However, I can’t ignore the vital take-aways from the 10 year FCPA investigation into Total S.A. (Total),...more

7/30/2013  /  Bribery , DOJ , FCPA , Iran , SEC , Settlement
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