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National Security Export Controls Iran

Orrick, Herrington & Sutcliffe LLP

DOJ implements its Data Security Program to protect users’ data

On April 11, the DOJ announced steps towards the implementation of a national security program aimed at protecting Americans’ sensitive data from China, Russia, Iran and other foreign adversaries. The Data Security Program,...more

American Conference Institute (ACI)

[Event] 19th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance - April 30th - May 1st, Washington, DC

With unprecedented change and intensifying enforcement, now is the time to ensure your team is prepared for what’s ahead. Ensure that you don’t miss out on critical U.S. and international economic sanctions updates and the...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

Seward & Kissel LLP

President Trump Seeks “Maximum Pressure” on Iran Through Expansion of Sanctions Targeting Iran’s Oil Exports

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As has been widely reported, the U.S. policy of “maximum pressure” towards Iran has returned. On February 4, 2025, the Trump administration (the “Administration”) issued a national security memorandum (the “Memorandum”)...more

Husch Blackwell LLP

Week Three in Trade – First 100 Days of the New Administration

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We previously covered President Trump’s IEEPA tariffs and the various retaliatory tariff and nontariff countermeasures announced by each country in separate posts. Currently, the Mexico and Canada tariffs have been paused...more

Alston & Bird

President Trump Renews “Maximum Pressure” Approach to Iran

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President Trump issued a new Executive Order renewing a commitment to imposing “maximum pressure” on the Iranian government to “end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist...more

Akin Gump Strauss Hauer & Feld LLP

National Security Presidential Memorandum/NSPM-2 (Trump EO Tracker)

Imposes maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop its support for terrorist groups. Relevant Secretaries are required to impose and enforce sanctions,...more

Troutman Pepper Locke

BIS Export Enforcement's 2024 Year in Review: Strengthening US National Security Through Strategic Action

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On January 2, 2025, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) Export Enforcement published its 2024 Year in Review, spotlighting key accomplishments in protecting U.S. national security. In this...more

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

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Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

Eversheds Sutherland (US) LLP

National Security Act of 2024 extends statute of limitations for sanctions violations to 10 years

The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran - The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - March 2024

On February 24, the two-year anniversary of Russia’s invasion of Ukraine, the Biden administration issued hundreds of new Russia-related export controls and sanctions. The Office of Foreign Assets Control (OFAC) and the...more

Goodwin

The BIOSECURE Act and Its Potential Implications

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Proposed federal legislation known as the BIOSECURE Act is being considered in both the U.S. House of Representatives and the U.S. Senate....more

Wiley Rein LLP

BIS Expands Export Control Restrictions on Russia, Belarus, and Iran

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On January 23, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released a new rule to expand and strengthen its existing export control restrictions under the Export Administration Regulations...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – July 2023 Update

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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

Holland & Knight LLP

Tri-Seal Compliance Note Issued on Export Controls, Sanctions Violations Self-Disclosures

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The U.S. Department of Justice (DOJ), Department of Commerce's Bureau of Industry and Security (BIS) and Department of the Treasury's Office of Foreign Assets Control (OFAC) on July 26, 2023, issued a Tri-Seal Compliance Note...more

Foley Hoag LLP

Navigating the International Trade & National Security Landscape

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The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...more

Dorsey & Whitney LLP

U.S. Government Expands Restrictions on Exports to China, Iran, and Russia and Issues New Business Advisory Regarding Forced Labor...

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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

Morrison & Foerster LLP

DOJ Announces Resolution Of First-Ever Voluntary Self-Disclosure Related To Export Control And Sanctions Violations

On April 29, 2021, the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the District of Massachusetts (collectively, “DOJ”) announced that DOJ entered into a precedent-setting...more

The Volkov Law Group

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

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In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program....more

Hogan Lovells

BIS adds a number of companies to the Entity List, including Iran Air

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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

Morrison & Foerster LLP

INSTEX and Europe’s “Legitimate Trade” with Iran - Skepticism prevails as Instrument for Supporting Trade Exchanges (INSTEX) is...

Three weeks ago, France, Germany, and the United Kingdom (the “E3”) created INSTEX SAS (Instrument for Supporting Trade Exchanges, INSTEX), an entity designed to enhance business between the EU and Iran and to serve as a core...more

Morrison & Foerster LLP

Iran Sanctions: Snap-Back, Part 2

Executive Summary - On November 5, 2018, the United States enacted the second of two powerful phases of the “snap-back” of Iran sanctions, re-imposing sanctions that were lifted by the United States in 2016 as a result of...more

Skadden, Arps, Slate, Meagher & Flom LLP

"US Announces Record-Setting Penalties for Violations of Export Controls and Economic Sanctions"

On March 7, 2017, the United States announced that China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd. and their respective affiliates (collectively, ZTE) had agreed to a record...more

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