Shoulder by Shoulder
In connection with the recently negotiated deal releasing five U.S. citizens wrongfully imprisoned by the government of Iran, on September 18, the U.S. government announced the establishment of a humanitarian channel (HC) in...more
Recognizing that COVID-19 is further straining humanitarian needs in sanctioned countries and complicating compliance with economic sanctions, and perhaps also in response to reports that US sanctions are hindering COVID-19...more
Despite the sobering news reports on the global spread of COVID-19, companies are continuing to try to conduct operations as (relatively) normally as possible. International business is particularly affected given the...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
The Treasury Department on October 25, 2019, imposed a ban on correspondent account relationships involving Iranian financial institutions under Section 311 of the USA PATRIOT Act – activities that were already prohibited by...more
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
Europe has come up with a nifty plan to help Iran buy and sell stuff outside the reach of U.S. sanctions. The problem is that the plan is a fraud magnet. How do we know? It’s been tried before, and the fraud was epic. The...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
On August 7, 2015, the U.S. Government issued a revised Guidance regarding Iran and also issued a Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry. The bottom...more