On October 8, 2020, the Treasury Department’s Office of Foreign Assets Control (OFAC) took a long-rumored final step in curtailing virtually all non-humanitarian financial flows with Iran, identifying the Iranian “financial sector” as a target for potential “secondary” sanctions designation, and simultaneously designating eighteen Iranian financial institutions, many of which had been the only
Iran
Iran Triggers Dispute Resolution Mechanism Under JCPOA
By Dj Wolff, Nicole Succar, Erik Woodhouse & Brian McGrath on
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…
OFAC Publishes Additional Iran-Related FAQs Related to Executive Order 13902
By Caroline Brown & Brian McGrath on
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…
OFAC Issues Fact Sheet Regarding Humanitarian Trade Involving Sanctioned Countries and Provides COVID-19 Guidance
By Caroline Brown, Carlton Greene, Jeffrey L. Snyder, Dj Wolff, Clif Burns, Nicole Succar, Erik Woodhouse & Nimrah Najeeb on
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…
Iran Petroleum and Petrochemical Designations
By Dj Wolff, Nicole Succar, Caroline Brown & Carlton Greene on
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…
Webinar: “Virtual” Sanctions Compliance: Managing Your Team and Getting Your Regulatory Updates While Remote
By Dj Wolff & Nicole Succar on
WEBINAR – REGISTER HERE
Thursday,
April 2, 2020
11:00am – 12:00pm EDT
Join us for a “couch side chat” for tips on how to effectively manage your sanctions compliance program virtually. We will also provide recent sanctions developments you might have missed while we were busy following important health news.
Tips Will Include:
- Best practices
…
Escalating Tensions in the Middle East: U.S. and EU Sanctions Developments on Iran
By Carlton Greene, Jeffrey L. Snyder, Dj Wolff, Nicole Succar, Erik Woodhouse & Nimrah Najeeb on
Keeping pace with the rapidly changing geopolitics in the region, the last week has brought a series of Iran-related sanctions developments with which global businesses need to keep up. First, on January 10, the United States further escalated sanctions against Iran, creating new designation authorities for those “operating in” Iran’s construction, mining, manufacturing, and textile…
FinCEN Identifies Iran as Money Laundering Threat While OFAC Announces New Mechanism to Facilitate Humanitarian Assistance There
On Friday, October 25, 2019 the Financial Crimes Enforcement Network (FinCEN) issued a final rule pursuant to Section 311 of the USA PATRIOT Act finding Iran to be a jurisdiction of primary money laundering concern and imposing special measures prohibiting U.S. financial institutions from maintaining correspondent accounts for or on behalf of Iran. Separately on…