On March 19, the Office of Foreign Assets Control (“OFAC”) issued a general license under the Iranian Transactions and Sanctions Regulations that authorizes several specific forms of academic exchanges with Iran. The newly issued general license – General License G (the “License”) – authorizes qualifying U.S. colleges and universities to engage in certain transactions related … Continue Reading
U.S. persons traveling to Iran for business can now take heart, because they, as well as most laptops and smart phones, may do so without the need for a license. A recent amendment to the wordily-named “General License with Respect to Certain Services, Software, and Hardware Incident to Personal Communications” (formerly “General License D,” now … Continue Reading
When the U.S. State Department late last month announced the administrative debarment of a former senior export compliance officer from Honeywell International, Inc. (“Honeywell”), reports on and analyses of the event focused on the multiple allegations of what went wrong. This was with good reason: any time a significant case of export noncompliance comes to … Continue Reading
On November 23, 2013, the White House issued a Press Release (“the Announcement”) outlining the first of a two-step negotiation process between Iran and the United States, the United Kingdom, Germany, France, Russia, and China (the “P5+1”). The Announcement calls for the P5+1 countries to provide limited sanctions relief to Iran in exchange for Iran’s … Continue Reading
When your work involves export controls, it’s good to remember that reform – especially in the form of decontrol – seldom has an immediate impact. It’s been just over a year since the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) lifted its restrictions on the export and re-export of certain medicines and medical … Continue Reading
On October 10, 2013, the U.S. District Court for the District of Columbia issued an amended ruling dismissing Ralls Corporation’s (“Ralls”) challenge to a presidential order requiring divestiture of its interest in four companies engaged in developing wind farms near a Naval base in Oregon. After the deal concluded, Ralls – a Delaware corporation privately … Continue Reading
As members of the United Nations prepared to descend upon Manhattan’s East Side, the U.S. government was moving to seize a building only 13 blocks away. On Monday, September 16, 2013, following a civil complaint originally filed in 2008 by the Manhattan U.S. Attorney’s Office, the U.S. District Court for the Southern District of New … Continue Reading
This post was also written by Matthew J. Thomas. ING Bank N.V., a Dutch financial institution, has agreed to pay $619 million in a settlement with the Treasury Department’s Office of Foreign Assets Control (OFAC), the Department of Justice (DOJ) and the Manhattan District Attorney. The settlement is the result of OFAC’s investigation into an … Continue Reading
On July 11, 2012, the Office of Foreign Assets Control (“OFAC”) implemented two general licenses authorizing the exportation of financial services and new investment in Burma (Myanmar). These general licenses follow earlier announcements that the U.S. government would take steps to ease sanctions on Burma, and follows the lead of Canada and the European Union. … Continue Reading
On July 10, 2012, OFAC announced that Great Western Malting Co. (“Great Western”), a U.S. company, agreed to pay $1.35 million to settle apparent violations of the Cuban Assets Control Regulations. Great Western produces malt for the brewing, distilling and food markets. OFAC’s settlement announcement indicates that Great Western’s U.S.-based personnel provided back-office support for a … Continue Reading
The U.S. Office of Foreign Assets Control (“OFAC”) and Bureau of Industry & Security (“BIS”) announced today that it has reached a settlement with ING Bank N.V. (“ING”) relating to potential liability under various U.S. sanctions against Burma (Myanmar), Cuba, Iran, Libya, and Sudan. The apparent violations date back to conduct that begin in 1994 … Continue Reading
On May 17, U.S. Secretary of State Hillary Clinton announced in remarks with the foreign minister of Burma (Myanmar) that the U.S. government will be taking action to ease sanctions on Burma in the form of a new general license. A general license is similar to an exception to the sanctions and authorizes the performance … Continue Reading
This post was also written by Anne Borkovic. The United States Congress is currently considering legislation that would increase the scope and application of the U.S. sanctions against Iran: The Comprehensive Iran Sanctions, Accountability and Divestment Act of 2009 (S. 2799) and the Iran Refined Petroleum Sanctions Act of 2009 (H.R. 2194). These changes could significantly … Continue Reading
