On June 25, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 50 entities and individuals comprising an expansive “shadow banking” network used by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and Islamic Revolutionary Guard Corps (IRGC) to gain access to the international financial system, and added

Last Friday, the U.S. Departments of Commerce, Justice, State, and the Treasury issued a joint guidance sheet on Iran’s unmanned aerial vehicles (“UAVs”) program (the “Iran UAV Guidance”). The Iran UAV Guidance highlighted (I) the threat Iran’s UAV program poses; (II) the key items that Iran relies on to expand its UAV program; (III) the

New U.S. Designations: On October 26, 2022, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) designated nine individuals and twelve entities for their involvement in the Russian Federation’s corruption and influence campaign in Moldova.  The designations included Igor Yuryevich Chayka, and Ivan Alesksandrovich Zavorotnyi, an associate of Chayka, for their

On January 13, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated “two organizations, along with their leaders and subsidiaries, controlled by the Supreme Leader of Iran, the Execution of Imam Khomeini’s Order (EIKO), and Astan Quds Razavi (AQR).”

Although both purported to be charitable organizations (bonyads), Treasury states, “EIKO and

On July 3, 2020 Iran initiated a dispute resolution mechanism contained in the Joint Comprehensive Plan of Action (JCPOA), more commonly referred to as the Iran nuclear deal, to address concerns over implementation of the deal. The EU’s Foreign Policy Chief stated that he had received a letter from Iran triggering the dispute mechanism over

On June 5, 2020, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published four new Frequently Asked Questions (“FAQs”) related to Executive Order 13902 (“EO 13902”) that may be particularly insightful for those companies that still do business involving Iran. The EO, first issued on January 10, 2020, imposed, in part, additional

On April 20, 2020, the U.S. Attorney for the Southern District of New York (SDNY) announced that the Industrial Bank of Korea (IBK) agreed to a deferred prosecution agreement (DPA) and $51 million penalty related to a one-count felony information charging IBK with violating the Bank Secrecy Act (BSA). On the same day, the New

In response to criticism that sanctions are hampering the global response to the COVID-19 pandemic, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released new guidance to encourage those interested in humanitarian trade involving jurisdictions sanctioned by the United States to “avail themselves of longstanding exemptions, exceptions, and authorizations” pertaining to that

The U.S. Departments of State and the Treasury recently sanctioned several individuals and companies for their involvement in transactions in Iranian petrochemical products or petroleum, signaling the U.S. government’s continued intent to cut off funding for Iran’s malign activities, including those of the Islamic Revolutionary Guard Corps-Qods Force’s (IRGC-QF). This action was taken pursuant to

Former U.S. Treasury and Justice Department Lawyer Strengthens Anti-Money Laundering, Economic Sanctions, and CFIUS Practices

Washington, D.C. — February 20, 2020: Crowell & Moring is bolstering its anti-money laundering, economic sanctions, and CFIUS practices with the addition of Caroline Brown, former attorney in the U.S. Department of the Treasury and the U.S. Department of