News & Analysis as of

Corporate Counsel Iran Sanctions

Wilson Sonsini Goodrich & Rosati

2021 U.S. Sanctions Year in Review

In January 2021, President Biden was sworn into office and for the first time in a decade, Democrats assumed control of both chambers of Congress. Notwithstanding these changes, the U.S. government has continued to rely on...more

Latham & Watkins LLP

Top EU Court Clarifies Anti-US Sanctions “Blocking Statute”

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The court explains how the controversial EU law operates to bar EU persons from complying with US sanctions on Iran and Cuba. On 21 December 2021, the Court of Justice of the European Union (CJEU) released its long-awaited...more

American Conference Institute (ACI)

[Complimentary Webinar] Mitigating Sanctions and Export Control Risks for Life Sciences, Research Institutes and Universities -...

Global life sciences companies, research institutes, and universities face unique challenges when complying with U.S. and non-U.S. trade control laws, including complying with general and specific licenses authorizing...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

BCLP

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

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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

The Volkov Law Group

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

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In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

Kelley Drye & Warren LLP

Recent OFAC Settlement Highlights Due Diligence Expectations When Selling to Intermediaries

Last week, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with UniControl, Inc. (UniControl or “the company”) for shipping goods to European trading partners when UniControl knew or should have...more

Morrison & Foerster LLP

OFAC 2020 Year In Review

In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Sanctions/Export Controls Trends in 2020

This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more

The Volkov Law Group

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

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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

WilmerHale

OFAC Crystallizes Expectations for Sanctions Compliance

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On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more

Jones Day

Sanctions Enforcement Action Provides Incentives for Companies and a Warning for Individuals

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The Situation: Using a novel approach, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") concurrently designated a non-U.S. individual to the Foreign Sanctions Evaders ("FSE") List in connection...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Adds Iranian Bitcoin Exchangers’ Names and Wallet Addresses to SDN List, Ushers in “New Approach” to Sanctions Enforcement

• On November 28, 2018, OFAC designated two Iran-based individuals who helped exchange cryptocurrency (bitcoin) into fiat currency on behalf of alleged ransomware perpetrators who targeted U.S. businesses and municipal...more

Carlton Fields

UK Court Considers Whether Payment Of Insurance Claim Violates Iran Sanctions

Carlton Fields on

A court in the United Kingdom has issued a ruling considering the intersection of a clause in an insurance agreement meant to protect the insurer from obligations that would violate international sanctions regimes and the...more

Kelley Drye & Warren LLP

Between a Rock and a Hard Place: EU & Russia Move Forward with “Blocking Statutes” in Response to U.S. Exit from Iran Nuclear Deal

Sanctions blocking statutes being prepared by the European Commission (EC) and Russia could put companies in the middle of conflicting legal requirements, raising difficult and complex sanctions compliance decisions. ...more

Morgan Lewis

Federal Criminal Case Raises Provocative Questions on US Jurisdiction

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Can the US government criminally prosecute non-US persons for activities that constitute secondary Iranian sanctions violations with no alleged nexus to the United States?...more

Skadden, Arps, Slate, Meagher & Flom LLP

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

Sheppard Mullin Richter & Hampton LLP

The Table Flip: Trump, the Iran Nuclear Deal, and American Business

- A President Trump will have authority to reinstate sanctions lifted by the Iran Nuclear Deal as well as revoke certain authorizations provided for business with Iran. - Several economic and geopolitical factors may...more

Davis Wright Tremaine LLP

Violation of OFAC Reporting Requirements: “No Harm, No Foul”? No Way!

A recent enforcement action by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) against MasterCard International Incorporated (“MasterCard”) stands as a reminder of the importance of strictly...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

Bennett Jones LLP

Changes to Canada’s Iran Sanctions – Your Questions Answered (and a Flowchart)

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On February 5, 2016, the Government of Canada amended its economic sanctions on Iran to significantly ease restrictions on doing business. The changes were in response to Iran’s compliance with its the commitments to restrict...more

Latham & Watkins LLP

Top 10 Things to Know About the Implementation of the Iran Nuclear Agreement

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The EU and UN terminate most of their sanctions on Iran, while the US implements more limited changes to its longstanding embargo. On January 16, 2016, the International Atomic Energy Agency (IAEA) verified that Iran...more

Holland & Knight LLP

Impact of Iran Accord on International Business - Briefing the "C" Suite on the Joint Comprehensive Plan of Action with Iran

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On July 14, 2015, the United States, France, China, Russia, the United Kingdom, Germany and the European Union (EU) entered into the Joint Comprehensive Plan of Action (JCPOA) with Iran after years of difficult negotiations....more

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