In 2023, the European Union continued to use economic sanctions as one of its foreign policy tools, and not only in response to Russia’s war in Ukraine. New sanctions and adjustments to existing regimes reflect the EU’s...more
Over an eight-year period ending in 2018, Murad, a U.S. cosmetics company, illegally exported goods and services to Iran in 62 separate transactions worth approximately $11 million. Murad was acquired by Unilever United...more
We are pleased to announce that our team’s fourth-annual international trade law year-in-review report was published just before the New Year. In it, we take a detailed look at how 2022 played out and explore how 2023 might...more
Current Situation in Iran - A historic and powerful popular movement—led by women in response to the murder of Mahsa Amini while in the custody of the Iranian Morality Police in mid-September—is currently unfolding in...more
As of August 29, there is renewed optimism that the EU, the US, and Iran are on the verge of reviving the Joint Comprehensive Plan Of Action (JCPOA) to limit Iran’s ability to develop nuclear weapons in exchange for a lifting...more
Talks between the U.S. and Iran to revitalize the nuclear deal may have stalled but they are far from dead. There is still optimism that the agreement to limit Iran’s ability to make weapons-grade uranium, in return for a...more
This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more
The European Union Blocking Statute was originally adopted in 1996 to counteract US sanctions on Cuba, Iran and Libya, but following a memorandum of understanding entered into between the EU and the US, it has seldom been...more
Top EU Court Rules on the EU Blocking Regulation Against US Sanctions for the First Time - On December 21, 2021, the Court of Justice of the European Union (CJEU), sitting as a “Grand Chamber” (a formation used, among...more
Over the past few weeks, we have been speculating on the international trends and tides we expect to see in the next four years under a new U.S. presidential administration. So that you can enjoy our prognostications (before...more
Report on Supply Chain Compliance 3, no. 21 (October 29, 2020) - The United States announced a “snapback” of United Nations (UN) sanctions on Iran due to Iran’s alleged noncompliance with the Joint Comprehensive Plan of...more
Doubling down on an America First foreign policy, a second term for President Trump would focus on continued unwinding post 9/11 military involvement in the Middle East while pursuing normalization of ties between Israel and...more
Report on Supply Chain Compliance 3, no. 19 (October 1, 2020) - The United States argued before the United Nations (UN) that Germany, France and the United Kingdom must support the U.S. demand to reimpose UN sanctions on...more
Summary - After the United Nations Security Council (“UNSC”) declined to extend a conventional arms embargo on Iran, the United States sought to unilaterally trigger a UN sanctions “snapback” provision and issued a new...more
On 31 March 2020, the Governments of France, Germany, and the United Kingdom (the so-called "E3") confirmed that the first transaction was completed through the Instrument in Support of Trade Exchanges ("INSTEX"),...more
As we mentioned in the first part of our U.S. Sanctions Year in Review series, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) had an extraordinarily busy year in 2019, and its enforcement activity...more
The Situation: The Trump administration announced a new round of sanctions on January 10, 2020, following escalating tensions between the United States and Iran. The Result: The new sanctions complement existing sanctions...more
In a January 14th Executive Order, President Trump expanded sanctions on Iran after a ballistic missile attack on two American military bases in Iraq. Executive Order 13902 expands secondary sanctions on Iran to capture...more
France, Germany and the United Kingdom, known as the “E3”, announced on 14 January 2020 that they had triggered the dispute resolution mechanism under the Joint Comprehensive Plan of Action (“JCPOA”) due to concerns about...more
With new Iran-related sanctions, the U.S. government is making good on threats to give third-country companies a choice – participate in the U.S. market or participate in the Iranian market. ...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
OVERVIEW - - Oversight of Foreign Investment & Tech Transfer - CFIUS Reforms – FIRRMA - Investment Strategies FOREIGN INVESTMENT & TECH OVERSIGHT - - The Committee on Foreign Investment in the United States...more
With tensions rising in the Persian Gulf, and Iran on the brink of pulling out of portions of the Iran nuclear deal, President Trump issued new Executive Order 13871 last Wednesday, May 8, 2019, imposing sanctions on Iran’s...more
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
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