News & Analysis as of

Iran Office of Foreign Assets Control (OFAC) Due Diligence

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2024 Lessons Learned and 2025 Expectations

As the third month of the second Trump administration comes to a close, the lack of any public enforcement action by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctions watchers...more

Venable LLP

OFAC Issues Sanctions Compliance Guidance and Scenarios for U.S. and International Maritime Industry

Venable LLP on

On October 31, 2024, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued scenario-based guidance specific to the maritime shipping industry....more

Lowenstein Sandler LLP

U.S. Government Issues Updated Sanctions Warning to Maritime Shipping Community; Recommends Best Practices to Mitigate Risk

Lowenstein Sandler LLP on

On May 14, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of State, and the U.S. Coast Guard issued a Sanctions Advisory for the Maritime Industry, Energy and Metals...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

Akin Gump Strauss Hauer & Feld LLP

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

Perkins Coie

Court Opinion on Liability for Re-Exports to Iran Spurs Practical Guidance for U.S. Exporters

Perkins Coie on

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more

Williams Mullen

“Reason To Know” – A Chilling Term For Exporters

Williams Mullen on

It’s a simple question – if a U.S. exporter sells its product to a foreign customer, and the customer resells the product to a prohibited country such as Iran, can the U.S. exporter have liability for an export violation? ...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

Baker Donelson

Iran – Don’t Forget the General License!

Baker Donelson on

Iran entered into a historic nuclear agreement with the U.S. and other world powers on July 14th 2015. The agreement will allow the licensing of the export, re-export, sale, lease or transfer to Iran of commercial passenger...more

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