Archives: Iran Sanctions

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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

President Signs Hezbollah Sanctions Bill Into Law

On December 18, President Obama signed into law the Hizballah International Financing Prevention Act of 2015 (HR 2297), which requires the President to impose sanctions on non-US financial institutions determined to be facilitating significant financial transactions for Hezbollah or its designated affiliates.  The law also directs certain federal agencies to submit reports to Congress with regard to … Continue Reading

On Our December 10 Iran Sanctions Seminar, and Thoughts on the Road Ahead

Thanks to all of the speakers and attendees at our December 10 London seminar “Transatlantic Perspectives on the Iran Nuclear Deal and Sanctions Compliance.” Approximately 170 attendees joined to hear the advertised keynote speaker Adam Szubin, US Treasury Acting Under Secretary for Terrorism and Financial Intelligence (and former OFAC Director), and to hear further remarks … Continue Reading

Congress Expected to Pass Visa Bill with JCPOA Implications

On December 15, 2015, Speaker of the House Paul Ryan (R-WI) announced that Congress reached agreement on a $1.1 trillion FY 2016 omnibus spending bill (HR 2029), which included a controversial provision that could have implications for the Joint Comprehensive Plan of Action (“JCPOA”).  Division O, Title II contains the Visa Waiver Program Improvement and … Continue Reading

Upcoming Webcast: 2015 Developments Regarding Economic Sanctions and Export Controls

Join us on Tuesday, December 15 for this complimentary webinar discussing economic sanctions, export control, and related developments over the past year.  Featured panelists include Steptoe International Compliance Blog contributors Alex Baj, Jack Hayes, Stephen Heifetz, Andy Irwin, Anthony Rapa, Meredith Rathbone, and moderator Ed Krauland. Date:   Tuesday, December 15, 2015 Time:   12:00 p.m. – 1:30 … Continue Reading

The IRGC and the Challenges of Entering the Iranian Market, Part 2

Following up on the previous post, companies seeking to do business in Iran following “Implementation Day” under the JCPOA will need to consider the impact of sanctions that will remain in place, including sanctions against Iran’s Revolutionary Guard Corps (IRGC).  Non-U.S. persons could face sanctions for doing business with the IRGC, which the U.S. Government … Continue Reading