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,
Temporary Fix: President Trump Extends the Iran Nuclear Deal
On January 12, 2018, President Trump issued a statement announcing that he will approve certain sanctions waivers necessary in order to preserve the Iran nuclear deal. At the same time, he called on the U.S.’s European allies to work with the U.S. to fix the flaws of the Iran nuclear deal (the Joint Comprehensive Plan
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
New Sanctions Despite Iran’s Compliance with the JCPOA
Last week the Trump administration announced new Iran-related sanctions imposed against 18 Iranian entities and individuals. The sanctions are the administration’s response to Iran’s ballistic missile program and destabilizing actions in the region.
The actions of the administration were taken pursuant to Executive Order (E.O.) 13382, which targets proliferators of weapons of mass destruction and
Senate Votes in Favor of Russia Sanctions
On Thursday, the Senate passed legislation to impose additional sanctions on Russia. The bill passed by an overwhelming majority, 98-2, with only Senator Rand Paul and Senator Bernie Sanders voting against it.
In addition to the Russian sanctions, Iran sanctions, and the requirement that Congress review any effort by the Trump administration to loosen sanctions
Imposing New Russian Sanctions
On Monday, U.S. senators reached an agreement regarding imposing new sanctions against Russia. The agreement will be filed as an amendment to a larger Iran sanctions bill that is nearing passage in the Senate.
The sanctions are meant to punish Russia for several
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
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
Seed Company Settles Claims with OFAC in “Egregious Case”
On September 13, 2016, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $4.3 million settlement with international seed producer and exporter PanAmerican Seed Company (“PanAm Seed”). In its official statement regarding the enforcement action, OFAC alleges that PanAm Seed faced statutory and civil penalties in the amount
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