News & Analysis as of

Office of Foreign Assets Control (OFAC) Iran National Security

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

The Volkov Law Group

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

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Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant. While OFAC had a slow year, DOJ...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

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

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

WilmerHale

Treasury Releases Long-Awaited Sanctions Policy Review

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The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...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

Bradley Arant Boult Cummings LLP

Facilitating Ransomware Payments Entails Sanctions Risks, OFAC Warns

The Treasury Department’s Office of Foreign Assets Control (OFAC) issued an advisory on October 1, 2020, warning companies that engage with the victims of ransomware attacks that they run the risk of violating U.S. sanctions...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

King & Spalding

Virtual Currency as a Threat to National Security?

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In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

Akin Gump Strauss Hauer & Feld LLP

Legal and Practical Considerations of the Trump Administration’s Designation of the IRGC as a Foreign Terrorist Organization

• On April 8, 2019, the U.S. government announced its intention to designate the Islamic Revolutionary Guards Corps (IRGC) as a Foreign Terrorist Organization, effective April 15, 2019. This unprecedented action will result...more

Jones Day

Impact of U.S. Withdrawal from the Iran Nuclear Deal

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The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran. The Result: All currently...more

The Volkov Law Group

New Sanctions Law Complicates Trade Compliance

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Politics and sanctions law go hand-in-hand. In a rare instance of bi-partisanship, Congress united to constrain the administration’s ability to modify the existing sanctions program against Russia. At the same time, Congress...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

Hogan Lovells

Trump Administration Takes Moderate Steps Against Iran. What Comes Next?

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On Friday, February 3, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced it was designating 25 entities and individuals as Specially Designated Nationals (SDNs) for their involvement in...more

Carlton Fields

The War Against Cyber Threats: President Obama Ups the Ante

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Focusing on overseas cyber threats, President Obama issued an Executive Order on April 1, 2015, which grants authorization to impose sanctions on individuals and entities engaged "in malicious cyber-enabled activities that...more

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