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Sanctions Round Up: Second Quarter 2015

After almost two years of negotiations, the P5+1 and Iran reach a final comprehensive agreement regarding Iran’s nuclear program, which will likely result in the gradual lifting of international and US sanctions by early next...more

Sanctions Round-Up: First Quarter 2015

In this edition: - US and EU continue targeting Russia for its activity in Ukraine - Cuba-related regulatory reforms announced - P5+1 and Iran reach framework agreement - US enforcement actions:...more

"Facilitation": A New Tool for Extraterritorial Sanctions Enforcement?

Recent OFAC and DOJ actions have focused on certain entities – overseas financial institutions – and particular conduct – US dollar clearing and associated “stripping.” The DOJ’s recent $232 million settlement and negotiated...more

Sanctions Round-Up: Fourth Quarter 2014

In this issue: - US and EU continue sanctions against Russia for its activity in Ukraine; - US and EU sanctions against the Crimea region; - US makes major change in Cuban relations; - The EU...more

Sanctions Round-Up: Third Quarter 2014

In this issue: - The Revised OFAC 50 Percent Rule - U.S. and E.U. Sectoral Sanctions Targeting Russia - Additional U.S. Sanctions Targeting Iran - Sanctions Targeting Ongoing Conflicts in Syria,...more

OFAC Settles Civil Enforcement Action with Dutch Company for Alleged Violations of US Trade Embargo on Cuba

The US Treasury’s Office of Foreign Assets Control (OFAC) and Carlson Wagonlit Travel B.V. (CWT), a Netherlands-based company, have agreed to settle violations of the Cuban Assets Control Regulations (CACRs) dating back to as...more

Sanctions Round-Up: First Quarter 2014

In this edition: - Implementation of the Joint Plan of Action with Iran - Additional US Iran-Related Sanctions and Licenses - OFAC Civil Settlements - US and EU Sanctions in Response to the Situation in...more

Sanctions Round-Up: Fourth Quarter 2013

As 2013 drew to a close, a potentially groundbreaking agreement was reached with Iran regarding its nuclear program, leading to much speculation about how certain sanctions might be suspended, and under what conditions. While...more

Iran Notices Update: SEC-Registered Issuers Continue to Adapt to Their New Normal

It has been over eight months since SEC-registered issuers began making mandatory disclosures of business activities in or with Iran. During that period, issuers have filed over 400 Iran Notices with the SEC, including...more

Sanctions Round-Up: Second Quarter 2013

In this issue: - The Iran Freedom and Counter-Proliferation Act of 2012 - E.O. 13645, issued June 3, 2013 - Enforcement Against Foreign Sanctions Evaders - Enforcement Against Human Rights...more

Sanctions Round-Up: First Quarter 2013

In this issue: - OFAC Releases New SDN Search Tool - Additional Provisions Targeting Iran Go Into Effect - OFAC Continues to Target Foreign Sanctions Evaders - Section 219 Disclosures Begin - Burma...more

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