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 US sanctions on Iran if the United States pulls out of the Joint Comprehensive Plan of Action (“JCPOA”). The US Congress built in a requirement under the Iran Nuclear Agreement Review … Continue Reading
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
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
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
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, 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
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
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
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
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
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
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
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
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 US history. However, heated rhetoric notwithstanding, he often spoke on the campaign trail of improving the deal, rather … Continue Reading
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 US economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he … Continue Reading
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
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-US, 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
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
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
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
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
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
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
On February 18, 2016, the Fifth Chamber of the European Court of Justice (ECJ) rendered a judgment in the matter of Council of the European Union v Bank Mellat (Case C-176/13 P) that could pave the way for Bank Mellat to recover damages based on its designation for sanctions by EU and UK authorities, and … Continue Reading
