News & Analysis as of

Foreign Financial Institutions (FFI) Iran

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions Iranian tech company and employees

On June 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13846, against an Iran-based technology company, two senior employees, and an affiliate based...more

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions network supporting Iran’s military programs

On April 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13382, against one individual and six entities involved in a sanctions evasion network...more

White & Case LLP

New Sanctions Target Iran’s Metals, Construction, Mining, Manufacturing, and Textiles Industries

White & Case LLP on

On January 10, 2020, the President signed a new Executive Order (EO), "Imposing Sanctions With Respect to Additional Sectors of Iran," targeting Iran's construction, mining, manufacturing, and textiles industries. On the same...more

Faegre Drinker Biddle & Reath LLP

President Trump Imposes Sanctions on Companies Doing Business with Iran’s Construction, Mining, Manufacturing and Textiles...

On January 10, 2020, President Trump issued a new Executive Order that imposes the latest in a series of economic sanctions on Iran. Individuals and entities violating these and other sanctions on Iran can face significant...more

Orrick, Herrington & Sutcliffe LLP

New Syria, North Korea and Other Sanctions Provisions Enacted as Parts of the National Defense Authorization Act for Fiscal Year...

On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more

Hogan Lovells

U.S. government announces enhanced due diligence process for humanitarian trade with Iran and identifies Iran as a jurisdiction of...

Hogan Lovells on

On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran. Foreign governments and foreign financial institutions...more

Ballard Spahr LLP

FinCEN Identifies Iran as a Jurisdiction of Primary Money Laundering Concern

Ballard Spahr LLP on

On October 25, 2019, FinCEN issued a final rule imposing the Fifth Special Measure against the Islamic Republic of Iran as a “jurisdiction of primary money laundering concern” (“Final Rule”) under Section 311 of the USA...more

Akin Gump Strauss Hauer & Feld LLP

Trump Administration Expands Sanctions Targeting Iran’s Industrial Metals Sector

• President Trump issued a new Executive Order (EO) on May 8, 2019—exactly one year after the Trump administration withdrew from the Iran nuclear deal—that widened the scope of existing sanctions targeting the Iranian...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

Eversheds Sutherland (US) LLP

Iran sanctions update – US announces it will not re-issue sanctions waivers for Iran oil imports to any country

On Monday, the United States announced that it would not extend the temporary waivers that were granted to eight countries last November allowing them to purchase Iranian oil without threat of sanctions. The temporary waivers...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

Eversheds Sutherland (US) LLP

US reimposes sanctions against Iran’s energy sector despite European opposition

As of November 5, 2018, US secondary sanctions against Iran are back in force, and more than 700 Iranian individuals and entities have been re-added or newly added to the US Specially Designated Nationals and Blocked Persons...more

Dechert LLP

End of the Road: U.S. Sanctions on Iran Come Back Into Effect

Dechert LLP on

On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more

Sheppard Mullin Richter & Hampton LLP

Client Alert: Iran Sanctions Are Back On: Can Business Continue?

On May 8, 2018, the United States withdrew from the Joint Comprehensive Plan of Action and reimposed all pre-JCPOA sanctions against Iran... After a prescribed wind-down period, all U.S. sanctions on Iran are now in force....more

Perkins Coie

FinCEN Advisory Emphasizes Importance of U.S.-Iran Sanctions and AML/CFT Compliance for Virtual Currency Businesses

Perkins Coie on

On October 11, 2018, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released an advisory (the Advisory) intended to help money services businesses (MSBs) and foreign financial institutions...more

Sheppard Mullin Richter & Hampton LLP

Client Alert: Iran Sanctions Return

1. All sanctions on Iran that were in place before January 2016 will be re-imposed no later than November, 4 2018. 2. Secondary sanctions that penalize non-U.S. persons doing business with Iran will be reinstated. 3....more

Jones Day

Impact of U.S. Withdrawal from the Iran Nuclear Deal

Jones Day on

The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran. The Result: All currently...more

Holland & Knight LLP

How Will the United States’ Withdrawal From the Iran Nuclear Accord Affect the Aviation Industry?

Holland & Knight LLP on

On May 8, President Trump announced that the United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA). The U.S. will reimpose sanctions suspended...more

Akin Gump Strauss Hauer & Feld LLP

President Trump Announces U.S. Withdrawal from JCPOA; U.S. Sanctions on Iran will be Re-imposed Following Wind-Down Periods

• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more

Sheppard Mullin Richter & Hampton LLP

Those Three Little Words: OFAC’s Subtle Language Shift Could Create Sweeping Change on Iran Investment

Article Highlights: - Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks. - Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United...more

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