In a May 22, 2018 Opinion and Order, the U.S. Court of International Trade (“CIT) upheld the U.S. Department of Commerce’s (“Commerce”) use of a Thai nail producer, rather than a Dubai producer, as a surrogate for the calculation of anti-dumping duties to be assessed on two nail producers from the United Arab Eremites
Alert: What U.S. Companies Need To Know About Renewed Iran Sanctions
On May 8, President Trump announced that the United States would withdraw from the Iran nuclear deal completed in 2015, otherwise known as the Joint Comprehensive Plan of Action (JCPOA). The scuttling of the deal re-imposes sanctions on the country that had been suspended as part of the agreement. In an Alert published Thursday,
OFAC Settles Iran Sanctions Claims
On Thursday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $415,350 settlement agreement with COSL Singapore Ltd. (“COSL”). The parties settled a potential civil liability claim for 55 apparent violation of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR), which took place between October 2011 and
Sanctions Penalty Reviewed by the D.C. Circuit Reversing $4M Penalty
Last week, the D.C. Circuit affirmed the U.S. Treasury Department’s Office of Foreign Assets Control’s (“OFAC”) wide latitude to impose Iran sanctions, but it set aside a $4.07 million penalty against car accessory seller Epsilon Electronics (“Epsilon”). The D.C. Circuit found that the agency cut too many corners in its investigation of Epsilon.
In July
OFAC Sanctions 271 Syrian Individuals
On Monday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) leveled one of the largest sanctions actions in OFAC’s history. OFAC sanctioned 271 employees of Syria’s Scientific Studies and Research Center (“SSRC”).
According to OFAC, the SSRC is responsible for developing chemical weapons that were used against civilians by Syrian government
Is OFAC Looking for Ways to Expand Its Jurisdiction?
In a recent enforcement action, the Treasury Department’s Office of Foreign Assets Control (OFAC), took what appears to be an unprecedented step in finding that a Taiwanese shipping company had violated the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR).
The
Lifting of Certain Sanctions Against Iran – What It Means for Foreign Subsidiaries of U.S. Companies
On January 16, 2016, the U.S. Department of State and the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) lifted certain nuclear-related “secondary sanctions” (sanctions targeting non-U.S. persons for certain Iran-related activities undertaken outside of the U.S.) against Iran pursuant to the Joint Comprehensive Plan of Action (JCPOA). This long awaited action
Iran Nuclear Deal – The Joint Comprehensive Plan of Action Formally Adopted (but not yet implemented)
The Joint Comprehensive Plan of Action (the JCPOA), between the so-called P5+1 countries (United States, United Kingdom, Germany, France, Russia and China) and Iran was formally adopted on Oct. 18, 2015 (Adoption Day) to lift certain sanctions on Iran. Please see our previous blog post