On November 5, the United States reimposed the final tranche of sanctions on Iran, which had been lifted pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) in 2016. The vast majority of these sanctions are “secondary sanctions,” being those which target non-U.S. persons and companies even where there is no U.S. nexus (e.g. the … Continue Reading
On 8 May 2018, President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA). In conjunction with that announcement, the President issued a National Security Presidential Memorandum (NSPM) directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. … Continue Reading
In the early hours of Tuesday, 7 August 2018, and as foreshadowed by President Trump’s announcement on 8 May 2018, the United States reimposed certain secondary sanctions on Iran, being those which apply to non-U.S. persons. The imposition of these sanctions follows the conclusion of a 90-day wind-down period and, as mentioned in our previous … Continue Reading
President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA) on 8 May 2018. In conjunction with that announcement, the president issued a National Security Presidential Memorandum directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. nexus. … Continue Reading
On February 2nd the Office of Foreign Assets Control (“OFAC”) imposed new sanctions on 13 individuals and 12 entities that were believed to be “involved in procuring technology and/or materials to support Iran’s ballistic missile program, as well as for acting for or on behalf of, or providing support to, Iran’s Islamic Revolutionary Guard Corps-Qods … Continue Reading
18 October 2015, marked ‘Adoption Day’ for the Joint Comprehensive Plan of Action (JCPOA). The JCPOA was agreed upon 90 days earlier, between the United States, Russia, China, the United Kingdom, France, and Germany, together with Iran. While the latest measures taken by the EU, the United States and Iran make the necessary legal preparations … Continue Reading
On 24 November 2013, the P5+1 countries (comprising the United States, Russia, China, the United Kingdom, France and Germany) together with Iran, agreed the Joint Plan of Action (JPOA), which relaxed some of the sanctions imposed against Iran by the EU and U.S. The JPOA was intended to provide interim sanctions relief, while the parties worked … Continue Reading
This post was also written by Laith Najjar. Since March 2014, we have been closely monitoring the developments relating to the situation in the Ukraine and reporting them as Client Alerts and blog updates. We have set out below a summary of the recent changes in respect of the Ukraine as well as an update … Continue Reading
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
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
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
On January 2, 2013, President Obama signed into law an act that imposes new sanctions on Iran. The new sanctions target certain entities and transactions, but largely focus on the energy, shipping, and shipbuilding sectors of the Iranian economy. Several of these provisions will become effective on July 1, 2013. Please click here to read … Continue Reading
This post was also written by Gunjan Talati and Joelle E.K. Laszlo. Guilt by association seems to be a growing trend in government contracts. Under this trend, states are starting to use their contracting authority to promote U.S. foreign policy and impose mandatory debarment for policy violators. In the latest example, companies doing business with Michigan … Continue Reading
In August of this year, President Obama signed the Iran Threat Reduction and Syria Human Rights Act of 2012. This law required presidential action to implement certain restrictions, and today, on October 9, 2012, President Obama issued a new Executive Order (EO): “AUTHORIZING THE IMPLEMENTATION OF CERTAIN SANCTIONS SET FORTH IN THE IRAN THREAT REDUCTION … Continue Reading
Late last night the U.S. Senate voted to approve the Iran Threat Reduction and Syria Human Rights Act of 2012, a vote which the House has taken and approved earlier in the day. The Act now awaits the signature of President Obama. As noted in our earlier coverage, this latest round of sanctions further targets … Continue Reading
This post was also written by Matthew J. Thomas and Charles A. Brown. Yesterday, Treasury’s Office of Foreign Assets Control (OFAC) made dozens of significant additions to its list if Iran-linked sanctioned parties, adding new energy, finance and shipping companies, as well as many new individuals and vessels. An update from our shipping, energy and commodities … Continue Reading
This post was also written by Matthew J. Thomas. Just ahead of this week’s meeting in Baghdad between Tehran and other nations concerning Iran’s controversial nuclear program, the U.S. Senate passed an Iran sanctions bill by a unanimous voice vote. This bill is the Senate counterpart to the “Iran Threat Reduction Act of 2011” (H.R. 1905), … Continue Reading
This post was written by Joelle E.K. Laszlo. What if you issued a general license and no one used it? The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has faced such a conundrum since March 2010, when it published a final rule amending U.S. regulations on Cuba, Iran, and the Sudan to … Continue Reading
This post was written by Matthew J. Thomas. US and EU sanctions continue to escalate on Iran and Syria, catching an ever-broadening group of global targets, as detailed in this latest update. While the EU continues to add dozen of names to its lists of blocked parties, the US today began imposing secondary sanctions on … Continue Reading
For everyone out there contracting with the State of California — here is a quick heads up. Remember way back in 2010 when Congress passed the Comprehensive Iran Sanctions, Accountability, and Divestment Act? Well, it turns out that California has decided to take advantage of the Divestment part. The Iran Contracting Act of 2010 requires … Continue Reading
This post was written by Anne Borkovic. After months of intense global negotiations, and facing increased sanctions from the United States, the EU, and the United Nations, what is life like in Iran? As expected, Iranians are experiencing increased gas prices, and the Iranian Revolutionary Guard is having some financing difficulties. Some of the more interesting effects, … Continue Reading
On July 1, 2010, President Barack Obama, preceded by Congressional voting signaling overwhelming support, signed into law the Comprehensive Iran Sanctions Accountability and Divestment Act (“Act”). The Act is an effort by the United States to hinder what appears to be Iran’s intent to develop nuclear weapons. Action by the United States comes at a … Continue Reading
