Archives: Iran Sanctions

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A Detailed Look at the Countering America’s Adversaries Through Sanctions Act

President Trump signed the Countering America’s Adversaries Through Sanctions Act into law on August 2, 2017, targeting Russia, North Korea, and Iran.  The law serves as a forceful, bipartisan statement that the US Congress continues to view robust economic sanctions as a foundation of US foreign policy, in which Congress will play a leading role … Continue Reading

UPDATE: Congress Passes Sweeping Iran, Russia, and North Korea Sanctions Legislation

On July 27, the Senate passed 98-2 the Countering America’s Adversaries Through Sanctions Act (HR 3364), which previously passed the House 419-3 on July 25, setting up  a showdown with President Trump. This bill is an omnibus of three separate sanctions measures: the Countering Iran’s Destabilizing Activities Act (“CIDAA”), the Countering Russian Influence in Europe … Continue Reading

Trump Administration Recertifies Iran’s Compliance with Nuclear Deal, Imposes Sanctions on IRGC-Linked Individuals and Entities

The Iran nuclear deal lives to see another day—but President Trump continues to express deep reservations regarding the agreement. Iran Nuclear Deal Certification On Monday, the Trump Administration reportedly certified Iran’s compliance with its nuclear-related obligations under the Joint Comprehensive Plan of Action (JCPOA) agreement, as required under the Iran Nuclear Agreement Review Act (INARA). … Continue Reading

Sanctions Round-Up

Sanctions, sanctions, and more sanctions– everyone’s favorite tool of foreign policy sure has been making a lot of news lately.  Here’s a round-up of the latest sanctions analysis here at the International Compliance Blog: Russia: Peter Jeydel summarized the Russia sanctions bill that the Senate passed on June 14, while Alexis Early assessed the bill’s prospect for passage … Continue Reading

Congress Flexes Sanctions Muscles: Bills Target Iran, Russia, and Others

This month, Congress is considering an array of new sanctions-related legislation, and, in recent days, bipartisan support has grown for a bill that would potentially direct significant measures against Russia and Iran. Congress has also debated bills proposing new sanctions against North Korea, Hamas, Hezbollah, and both chambers have put forth multiple bills that would … Continue Reading

Epsilon Electronics: A Cautionary Tale on Transshipments?

On May 26, 2017, in Epsilon Electronics v. US Department of the Treasury, a split panel of the DC Circuit Court of Appeals partially upheld and partially remanded to the district court a determination by the Treasury Department’s Office of Foreign Assets Control (OFAC) to impose a penalty of over $4 million against Epsilon for … Continue Reading

Trump Administration Certifies Iran’s Compliance with Nuclear Deal, but Initiates Review of Sanctions Relief

Will the Trump Administration “waive” goodbye to sanctions relief under the Iran nuclear deal? Last night, Secretary of State Rex Tillerson certified to Congress that Iran is in compliance with the Joint Comprehensive Plan of Action (JCPOA) agreement regarding Iran’s nuclear program, but signaled that the Trump Administration is reviewing whether continued sanctions relief under the … Continue Reading

New Iran Sanctions Bills Backed by Bipartisan Group of Key Legislators

On March 23, 2017, members of Congress introduced two new bills aimed at increasing non-nuclear sanctions against Iran. While several Iran sanctions bills have been introduced since the start of the year, these newly introduced bills are particularly notable due to their bipartisan support from an influential group of legislators. The bills represent legislative compromises … Continue Reading

OFAC Takes Sanctions Jurisdiction Into Uncharted Waters

On February 3, 2017, the US Treasury Department’s Office of Foreign Assets Control issued a finding of violation against Taiwan-based B Whale Corp. (BWC), a member of the Taiwan-based shipping company TMT Group. The finding of violation was issued for activity occurring entirely outside the United States, based on the jurisdictional finding that “BWC was … Continue Reading

Potential Designation of the IRGC as a Foreign Terrorist Organization and What It Could Mean for the Iran Deal

The Trump Administration recently floated the idea of designating Iran’s Islamic Revolutionary Guard Corps (IRGC) and the Muslim Brotherhood as Foreign Terrorist Organizations (FTOs).  This post focuses on the potential designation of the IRGC as an FTO, while a future post will discuss the implications of designating the Muslim Brotherhood as an FTO. The IRGC … Continue Reading

New US Sanctions on Iran: More of the Same, but Tensions Are Rising

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 25 additional individuals and entities on its list of Specially Designated Nationals and Blocked Persons (SDNs) on February 3, 2017.  Alone the new designations do not constitute a departure from past policy or practice, but they could indicate the possibility of such … Continue Reading

Waive it Goodbye? How the Trump Administration Might Attack the Iran Nuclear Agreement

President Trump has made no effort to conceal his disdain for the Joint Comprehensive Plan of Action (JCPOA) agreement regarding Iran’s nuclear program, which he frequently has described as a “disaster” ranking among the worst deals in U.S. history. However, heated rhetoric notwithstanding, he often spoke on the campaign trail of improving the deal, rather … Continue Reading

What to Expect for Economic Sanctions Under President Trump?

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he … Continue Reading

Iran Sanctions Extension Act Becomes Law without President Obama’s Signature

On December 15, 2016, the White House Press Secretary released a statement that President Obama would allow the Iran Sanctions Extension Act (H.R. 6297) to become law, but that the President declined to sign it.  This bill extends the current Iran Sanctions Act (ISA) through December 31, 2026 and passed Congress with overwhelming support, passing the … Continue Reading

OFAC Sets Out 180-Day Wind Down Period if Iran Sanctions “Snap Back”

On December 15, 2016, OFAC amended Frequently Asked Question (FAQ) No. M.5 to provide more clear guidance about how it would treat business activities in Iran by non-U.S., non-Iranian persons should those activities become prohibited or sanctionable as a result of a “snapback” into effect of economic sanctions provisions that are currently modified or suspended … Continue Reading

What a Trump Administration Could Mean for International Regulatory Compliance

After the November 8, 2016 elections, Washington is preparing for a new Congress and the transition of power from eight years of the Democratic Obama administration to the Republican administration of President-elect Donald Trump.  As the incoming president builds his transition team and sets out his policy priorities, Steptoe will examine what these changes may … Continue Reading

How the 2016 Election Will Impact Public Policy Developments

Sunday’s presidential town hall debate was the second of three opportunities for candidates Donald Trump and Hillary Clinton to make their case to the American electorate.  In addition to the discussion of personal and character issues, the candidates touched on a range of policy issues, including tax policy, financial services, energy, and international trade.  The … Continue Reading

“Egregious” Sale of Flower Seeds to Iran Shows No Sector is Immune from OFAC

The Treasury Department’s Office of Foreign Assets Control (OFAC) reached a $4,320,000 civil settlement with PanAmerican Seed Company (PanAm Seed) for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR) that occurred between 2009 and 2012. OFAC treated this as an “egregious case,” which may raise eyebrows because it involved the export of seeds, … Continue Reading

Federal District Court Sides with OFAC in Rare Judicial Challenge of Sanctions Violations Penalty

On March 7, 2016, the United States District Court for the District of Columbia granted the US Government’s motion for summary judgment in Epsilon Electronics, Inc. v. United States Department of the Treasury, Office of Foreign Assets Control, upholding a $4.073 million civil penalty imposed the Office of Foreign Assets Control (“OFAC”) on Epsilon Electronics, Inc. … Continue Reading

OFAC Issues a Finding of Violation Against MasterCard Over Reporting Requirements

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Finding of Violation to MasterCard on March 16 for failing to report accounts in which blocked entities held interest. The Finding of Violation represents a rare instance of enforcement of the Reporting, Procedures, and Penalties Regulations (RPPR). Although MasterCard had restricted … Continue Reading

OFAC Issues General License to Authorize Transactions Related to Contingent Contracts for Export of Commercial Passenger Aircrafts to Iran

On March 24, 2016, OFAC issued General License I (“GL I”) to authorize US persons to engage in transactions that are “ordinarily incident” to the negotiation of and entry into “contingent contracts” for the export or re-export to Iran of commercial passenger aircraft and related parts and services.  GL I requires that the performance of … Continue Reading

US, EU Implement Iran Sanctions Relief

The Joint Comprehensive Plan of Action between Iran and six world powers became effective on January 16, 2016 (“Implementation Day”), triggering significant sanctions relief in exchange for Iran curtailing its nuclear program.  While the EU has lifted most of its sanctions against Iran and the US has also eased a broad range of sanctions applicable … Continue Reading

US, EU Implement JCPOA Iran Sanctions Relief

Today, the International Atomic Energy Agency (“IAEA”) announced that Iran has met the first round of its nuclear-related commitments under the Joint Comprehensive Plan of Action (“JCPOA”).  As Steptoe explained when the JCPOA was agreed to between Iran and the P5+1 countries in July 2015, Iran would not receive any sanctions relief until “Implementation Day,” the … Continue Reading
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