Archives: Iran Sanctions

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US Withdraws from Treaty of Amity with Iran after International Court of Justice Imposes Limited Provisional Measures Against US Iran Sanctions

On October 3, 2018, the International Court of Justice (“ICJ” or the “Court”), the principal judicial organ of the United Nations, issued an Order ruling partly in favor of Iran on Iran’s request for provisional measures against the US for its May 8, 2018 withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”) and re-imposition … Continue Reading

EU Blocking Statute Takes Effect to Counter US Re-Imposed Sanctions on Iran

In response to President Trump’s Executive Order re-imposing certain Iran-related sanctions, summarized in our recent post, the EU has expanded the scope of the EU Blocking Statute to cover certain US Iran-focused sanctions.  On August 7, immediately following the US government’s re-imposition of certain Iran-related sanctions, the Commission Delegated Regulation (EU) 2018/1100 amending the annex … Continue Reading

Certain Iran Sanctions Reimposed after 90-Day “Wind-Down” Period Ends

President Trump issued an Executive Order today re-imposing and, in some cases, expanding sanctions on Iran that had been lifted under the 2016 nuclear deal (the “JCPOA”), as today marked the end of the first “wind-down” period of 90 days following the President’s May 8 announcement that the US would no longer honor its sanctions … Continue Reading

U.S. Rejects European Requests for Exemptions to Iran Sanctions

Since President Trump’s announcement, on May 8, that the United States would withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose previously lifted sanctions against Iran, the remaining JCPOA signatories have been scrambling to save the agreement. On June 4, officials from the UK, Germany, France, and the EU sent a letter to … Continue Reading

OFAC Revokes General License H and Takes Other Steps to Continue to Implement the US Withdrawal from the JCPOA

Effective yesterday, as part of the President’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the Office of Foreign Assets Control (OFAC) revoked several general authorizations that had been issued as part of the JCPOA, and amended the Iranian Transactions and Sanctions Regulations (ITSR) to implement “wind down” periods for persons who … Continue Reading

EU Extends the Scope of EU Blocking Statute to Protect Against Extra Territorial Application of US Re-Imposed Sanctions on Iran

On June 6, and in furtherance of its May 16 announcement, the European Commission adopted a delegated act to amend the annex to the EU Blocking Statute by adding within its scope US Iran-related secondary sanctions that have extra-territorial application.  The delegated act will enter into force once it is published in the EU Official … Continue Reading

In-Depth Advisory on President’s Announcement of Withdrawal From JCPOA and Reimposition of Nuclear-Based Sanctions on Iran

In addition to our previous updates, Steptoe recently published an in-depth advisory on President Trump’s May 8, 2018 decision to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA). The JCPOA is an agreement reached in July 2015 between Iran, the United States, the United Kingdom, France, China, Russia, and Germany in … Continue Reading

A Brief Explanation of the EU Blocking Statute Process in Support of the JCPOA

On May 18, the Commission announced the launch of the formal process to activate the EU “blocking statute” (Council Regulation (EC) 2271/96) by updating the list of US sanctions on Iran falling within its scope. The Commission starts the formal process after receiving unanimous informal support from the leaders of the EU Member States to … Continue Reading

EU Moves to Reactivate Blocking Statute, Launches Other Initiatives Regarding Iran

Here’s the official press release.  The EU Blocking Regulation, which in its heyday was only sparingly (if ever) enforced with respect to Iran, is now coming to the fore as one of the European Union’s key  tools to help EU companies cope with President Trump’s withdrawal from the JCPOA.  The European Union also announced other … Continue Reading

The Plot Thickens: EU Prepares to Invoke Blocking Regulation in Response to U.S. Withdrawal from JCPOA

As the world seeks to come to grips with President Trump’s withdrawal from the JCPOA, it appears that the European Union will play one of its strongest cards by invoking its “Blocking Regulation“, which would prohibit European companies from complying with U.S. sanctions against Iran.  European Commission President Jean-Claude Juncker had this to say: As the … Continue Reading

President Trump Withdraws United States from Iran Nuclear Agreement

Today, President Trump announced “that the United States will withdraw from the Iran nuclear deal” and issued a National Security Presidential Memorandum (NSPM) “to begin reinstating” the “highest level” of economic sanctions on Iran.  Today’s action sets in motion the termination of all or nearly all of the sanctions relief offered by the United States … Continue Reading

Newly Introduced Sanctions Bill Targets IRGC

On March 1, House Foreign Affairs Committee Chairman Ed Royce (R-CA) and the committee’s ranking Democrat, Eliot Engel (D-NY), introduced bipartisan legislation targeting Iran’s Islamic Revolutionary Guard Corps (“IRGC”), a branch of Iran’s armed forces considered responsible for much of Iran’s international terrorism and domestic repression.  The new bill, known as the Iranian Revolutionary Guard … Continue Reading

What if President Trump Refuses to Renew Iran Sanctions Waivers?

Last week, while reluctantly renewing waivers of statutory sanctions against Iran, President Trump issued an ultimatum: Either the United States’ European allies negotiate a “supplemental agreement” that strengthens the Joint Comprehensive Plan of Action (JCPOA) nuclear agreement and targets Iran’s ballistic missile program, or the United States will no longer waive sanctions against Iran.  The President’s … Continue Reading

President Trump Reissues Iran Sanctions Waivers, but Warns That Concerns over JCPOA Must Be Addressed

On January 12, President Trump announced that he was reissuing statutory waivers necessary to continue certain sanctions relief pursuant to the Joint Comprehensive Plan of Action (“JCPOA” or Iran nuclear deal), but stated that this was the last time he would reissue such waivers unless his concerns over the agreement were addressed.  On the same … Continue Reading

Economic Sanctions Webinar

On Wednesday, November 15 at 12:00 PM EST, Anthony Rapa will be presenting “Recent Developments in Economic Sanctions: Russia, Iran, Venezuela, North Korea, and Cuba,” a webinar hosted by Federal Publications.  As described on the Federal Publications website: From “decertifying” the Iran deal to disputes with “Rocket Man,” the economic sanctions world has seen dizzying … Continue Reading

Congress Continues Bipartisan Focus on Sanctions Legislation

The House of Representatives was the scene of a flurry of sanctions-related activity this week, as the lower chamber passed new sanctions measures related to North Korea, Iran, and Hizballah. The bipartisan consensus on sanctions policy in the House continued, with three of the bills passing by unanimous voice vote and the other two bills … Continue Reading

President Trump Decertifies Iran Deal, Outlines New Approach

As a follow up to our recent blog post, Steptoe published a detailed advisory on President’s Trump’s October 13, 2017 announcement that his administration would take a new strategic approach with regard to Iran and that he “cannot and will not” continue to make at least one of the periodic certifications regarding the Joint Comprehensive … Continue Reading

President Trump Outlines New Strategic Approach Regarding Iran

In a speech today, President Trump announced the result of his Administration’s strategic review of foreign policy towards Iran, including the Joint Comprehensive Plan of Action (“JCPOA”) implemented by the Obama administration in January 2016.  As set out in a White House fact sheet, the Trump Administration will seek to expand the focus of U.S. … Continue Reading

EU Raises Specter of Blocking Regulation as Trump Administration Ponders JCPOA

In a panel hosted by the Atlantic Council last week, the EU Ambassador to the United States, David O’Sullivan, stated that the European Union could block U.S. sanctions on Iran if the United States pulls out of the Joint Comprehensive Plan of Action (“JCPOA”). The U.S. Congress built in a requirement under the Iran Nuclear Agreement Review … Continue Reading

Settlement Points to Potentially Expansive View of Importation of Iranian Services by OFAC

On August 10, 2017, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with IPSA International Services, Inc. (“IPSA”) to resolve apparent violations of the Iranian Transactions and Sanctions Regulations (“ITSR”).   The apparent violations include importation of Iranian-origin services in violation of § 560.201 and engagement in transactions or dealings related … Continue Reading

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
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