News & Analysis as of

Iran Sanctions Office of Foreign Assets Control

Cross-Border Investigations Update - November 2017

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including new U.K. reporting obligations for sanctions violations,...more

Red Notice Newsletter - November 2017

ANTICORRUPTION DEVELOPMENTS – SBM Offshore N.V. Agrees to Pay $238 Million to Resolve DOJ FCPA Enforcement Action - On November 29, 2017, SBM Offshore N.V. (SBM), a Netherlands based company specializing in the...more

Status of Key U.S. Sanction Programs

by Miller Canfield on

Recently, many revisions to U.S. sanction programs (both implemented and under consideration) have been the topic of much public discussion. Often, the legal status or these revisions may be difficult to determine....more

Red Notice Newsletter - October 2017

ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more

Iran: Following President Trump’s “Decertification,” New U.S. Sanctions on Iranian Entities and All Eyes on the U.S. Congress

• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...more

Iran Speech Shifts Pressure to Congress, But Changes Little for U.S. Businesses

by Baker Donelson on

President Trump’s October 13 speech denounced Iran’s “fanatical regime” as a “menace,” and threatened to terminate the 2015 Iran nuclear deal negotiated by Barack Obama and formally known as the Joint Comprehensive Plan of...more

Federal Criminal Case Raises Provocative Questions on US Jurisdiction

by Morgan Lewis on

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

President Trump 'Decertifies' the JCPOA, but the US Remains a Party to the Deal

Pursuant to the Iran Nuclear Agreement Review Act of 2015 (INARA), the president is required to make certifications every 90 days that Iran is complying with its obligations under the Joint Comprehensive Plan of Action...more

Anti-Money Laundering and Bank Secrecy Act Update

by Moore & Van Allen PLLC on

After the Panama Papers exposed efforts by wealthy individuals and government officials to hide funds offshore, government authorities around the world have responded with new legislation, regulations and enforcement actions...more

Iran Nuclear Deal “Decertified” Although Impact Is Uncertain

by K&L Gates LLP on

On October 13, 2017, President Trump announced that he was “decertifying” Iran’s compliance with the Joint Comprehensive Plan of Action (“JCPOA”), the multi-nation agreement on Iran’s nuclear program that was implemented in...more

President Trump’s JCPOA Announcement Is More Complicated Than It Looks

by Alston & Bird on

On October 13, 2017, President Trump announced a new national security strategy regarding Iran that may eventually affect current economic sanctions restrictions involving Iran. The President in his comments noted that he...more

Today, President Trump Decertified the Iran Deal and Announced Tougher Sanctions on Iran

What does decertification mean? For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more

Sanctions Round Up: Third Quarter 2017

by Shearman & Sterling LLP on

The third quarter was headlined by the imposition of broad new US legislative sanctions against Russia, Iran, and North Korea. The Trump Administration also acted unilaterally to significantly expand sanctions against both...more

Red Notice Newsletter - August 2017

ANTICORRUPTION DEVELOPMENTS - MTS Receives DOJ and SEC Declination Letters Concluding FCPA Investigations - On August 7, 2017, MTS Systems (MTS), a Minnesota based maker of test systems and industrial position...more

Significant New Russia, Iran and North Korea Sanctions Legislation Signed Into Law

by K&L Gates LLP on

On August 2, 2017, President Trump signed into law the Countering American’s Adversaries Through Sanctions Act (the “Act”). Passed by overwhelming bipartisan majorities in both Houses of Congress, the Act combines several...more

OFAC Puts Companies on Notice: Due Diligence in Iran Can Trigger Sanctions Violations

• This enforcement action highlights the heightened sanctions compliance and enforcement risk that companies face when engaging third-party consultants to perform due diligence on counterparties. U.S. persons must make clear...more

OFAC Settles Iran Sanctions Claims

by Fox Rothschild LLP on

On Thursday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $415,350 settlement agreement with COSL Singapore Ltd. (“COSL”). The parties settled a potential civil liability claim...more

OFAC Pushes Iran Sanctions Enforcement

by Michael Volkov on

Many companies have been laser-focused on anti-corruption compliance, and with good reason given the risks and consequences of an anti-corruption enforcement action. In doing so, companies have to be careful to avoid ignoring...more

A New Trend? Singapore Company Targeted for U.S. Dollar Payments to Iranian Entities

by Jones Day on

The U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC") recently announced a settlement with CSE TransTel Pte. Ltd. ("TransTel"), a wholly owned subsidiary of CSE Global Limited ("CSE Global"), both of...more

US Enacts “Countering America’s Adversaries Through Sanctions Act” Expanding Its Russia, Iran, and North Korea Sanctions Programs

by White & Case LLP on

On August 2, 2017, the President signed into law the "Countering America's Adversaries Through Sanctions Act," providing a number of new sanctions against Russia, Iran, and North Korea. The President also issued a signing...more

OFAC Pushes New Limits on Jurisdiction of U.S. Sanctions by Penalizing Non-U.S. Companies for “Causing” Violations by Making U.S....

On July 27, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the civil settlement with CSE TransTel Pte. Ltd. (“TransTel”) and CSE Global Limited (“CSE Global”) in the amount of...more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation...more

Toughening of sanctions against Russia, Iran and North Korea: Ten key provisions (Russian and English)

by Latham & Watkins LLP on

President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions. On Wednesday, August 2, 2017, President...more

President Trump Signs New Sanctions Legislation into Law

by Jones Day on

On August 2, 2017, President Trump signed the "Countering America's Adversaries Through Sanctions Act" ("Act") into law. The Act, which codifies and strengthens sanctions against Russia and expands sanctions against Iran and...more

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