The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
Our International Trade team comments on additional restrictions on trade with Cuba
In this weekly update, we summarise the most notable updates in the UK sanctions world. ...more
On February 23, building mainly upon the broad authority of Executive Order 14024 (“EO 14024”)[1] issued by President Joe Biden in 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the...more
In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London...more
October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more
The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
On the one-year anniversary of Russia's invasion of Ukraine, the US imposed additional sanctions and export controls measures on Russia. The restrictions include a new determination targeting the metals and mining sector of...more
Broadening its response to Russia’s one-year-old assault on Ukraine, the United States announced additional export control and sanctions measures, effective February 24, 2023. These new measures expand restrictions on...more
On January 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an Iran-related frequently asked question (FAQ) and amended several other Iran-related FAQs. ...more
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
After Mahsa Amini was killed in the custody of “Gasht-e-Ershad” or Iran’s Guidance Patrol, commonly referred to as Iran’s morality police, following an arrest for placement of her hijab, protests have erupted throughout Iran...more
The Bureau of Industry and Security (“BIS”) in U.S. Department of Commerce has added 34 more companies to its Entity List in its continued expansion of U.S. export controls to address human rights in the Xinjiang Uyghur...more
OFAC is a steady enforcement agency. As the COVID-19 pandemic settled down, OFAC resumed aggressive enforcement of economic sanctions. ...more
Amazon joins the exclusive club of high-tech OFAC violators. Last year, Apple settled with OFAC for sanctions violations. This year, we can add Amazon to the list of OFAC violators. ...more
On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued four new frequently asked questions (“FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions...more
Huawei Charged in Racketeering Conspiracy and Conspiracy to Steal Trade Secrets; Temporary General License Extended – On February 13, 2020, Huawei Technologies Co. Ltd. (Huawei) and two of its U.S. subsidiaries were...more
As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List. Summary - Companies that use Iran Air as transport, particularly companies engaging in...more
On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under...more
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
Report on Supply Chain Compliance 2, no. 21 (November 7, 2019) - The U.S. Department of the Treasury’s Office of Foreign Assets Control issued General License K,[1] “Authorizing Maintenance or Wind Down of Transactions...more
With Brexit looming, the UK's autonomous sanctions policy is slowly taking shape. This month saw the publication of regulations setting out the post-Brexit UK sanctions regimes for Iran, Burma and Venezuela, which will come...more
In 2018, the United States continued to expand its sanctions programs and increase enforcement. While President Donald Trump’s decision to re-impose nuclear-related sanctions on Iran has perhaps drawn the most attention, key...more
On November 5, 2018 the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) completed the process to re-impose the Iran sanctions program. The 180-day wind-down period for termination of the United States’...more
• 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
As described in our prior alert, November 5, 2018 marked the full return ("snapback") of U.S. Iran-related sanctions measures lifted or waived pursuant to the Iran nuclear deal (the Joint Comprehensive Plan of Action or...more