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Sanctions Round Up: Fourth Quarter 2018

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

Sanctions Round Up: Third Quarter 2018

Russia remained at the forefront this quarter, as the Trump Administration imposed new measures and markets reacted to the threat of additional, “crushing” sanctions from Congress on Russian sovereign debt. Meanwhile, EU...more

Sanctions Round Up: Second Quarter 2018

This quarter, companies around the globe prepared to exit Iran-related business in the wake of U.S. sanctions snap-back. Meanwhile, OFAC provided a path to relief to designated Russian entities, extending several deadlines...more

President Trump Announces US Withdrawal from JCPOA

President Trump announced today the United States’ withdrawal from the Joint Comprehensive Plan of Action and initiated plans to re-impose nuclear-related sanctions that had been suspended under the terms of the 2015 nuclear...more

Section 219 Iran Notices Update: Disclosure Dynamics in the Era of Relaxed Iran Sanctions

It has now been two years since Iran-related sanctions relief took effect under the Joint Comprehensive Plan of Action. While U.S. persons continue to be generally prohibited from engaging in Iran-related business, the JCPOA...more

Sanctions Round Up: Fourth Quarter 2016 and President Donald J. Trump

On November 8, 2016, Donald John Trump was elected the 45th President of the United States. Following fiery criticism of the Obama Administration’s sanctions policies, including the Iran deal, the lifting of substantial parts...more

Iran Sanctions: OFAC Provides—at Least for Now—Assurances of a Wind-Down Period in Case of Snap-Back

On December 15, 2016, the Office of Foreign Assets Control revised its Frequently Asked Questions guidance that concerns the re-imposition of sanctions in the event of a sanctions snapback under the Joint Comprehensive Plan...more

Ramifications of US Election for International Sanctions

Yesterday’s election has significant implications for international sanctions, particularly with respect to Iran, Cuba, and Russia. Although we do not want to be unduly alarmist, President-elect Trump’s statements on the...more

Sanctions Round-Up: Fourth Quarter 2015 and “Implementation Day”

The International Atomic Energy Agency certifies that Iran had complied with all nuclear-related requirements of the Joint Comprehensive Plan of Action leading to the end of United States sanctions against the country...more

Navigating Iran Sanctions After Implementation Day

Although the United States, the European Union, and the United Nations lifted a number of sanctions targeting Iran on January 16, 2016 (“Implementation Day”) in accordance with the terms of the recent Iran nuclear deal, the...more

Iran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions

Although US and EU sanctions targeting Iran are not likely to be lifted before early 2016, there are a number of issues which US and EU-based financial institutions should be aware of in preparation for sanctions relief as a...more

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

Looking Forward to Lifting of Sanctions Against Iran

After almost two years of negotiations, on July 14, 2015, the E3/EU+3 (China, France, Germany, Russia, the United Kingdom and the United States) and Iran reached an agreement regarding Iran’s nuclear program. The Joint...more

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