On April 7, 2014, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published in the Federal Register a final rule amending the Iranian Transactions and Sanctions Regulations (ITSR) by expanding an existing general license that authorizes the exportation or reexportation of food to individuals and entities in Iran to include the broader category of agricultural commodities. The rule also clarifies and adds certain definitions in OFAC regulations. Finally, the rule adds a…
On April 1, 2014, the Department of State published in the Federal Register a notice [Public Notice 8678] informing the public that the Secretary of State determined on March 4, 2014, pursuant to Section 1245(d)(4)(D) of the National Defense Authorization Act for Fiscal Year 2012 (NDAA) (Public Law 112-81), as amended by the Iran Threat Reduction and Syria Human Rights Act (Public Law 112-158), that as of March 4, 2014, each of the following purchasers…
On March 19, 2014, the Office of Foreign Assets Control (OFAC) issued General License G to the Iran Sanctions to authorize certain academic exchanges and the exportation or importation of certain educational services. With certain exceptions, accredited graduate and undergraduate degree-granting academic institutions located in the United States (collectively, “US academic institutions”), including their contractors, are authorized to enter into student academic exchange agreements with universities located in Iran (collectively, “Iranian universities”) related to undergraduate…
On March 14, 2014, the Federal Register published Presidential Notice of March 12, 2014 – Continuation of the National Emergency With Respect to Iran. The Notice continues for 1 year the national emergency declared in Executive Order (EO) 12957 of March 15, 1995. On May 6, 1995, the President issued EO 12959, imposing more comprehensive sanctions on Iran to further respond to this threat. On August 19, 1997, the President issued EO 13059, consolidating and…
On March 11, 2014, the Office of Foreign Assets Control (OFAC) published in the Federal Register a notice publishing General License D-1 issued under the Iranian transactions sanctions program on February 7, 2014. General License D-1 authorizes the exportation, reexportation, or provision to Iran of certain services, software, and hardware incident to personal communications, subject to certain limitations, as well as the importation into the United States of certain software and hardware previously exported to…
On February 27, 2014, the Office of Foreign Assets Controls (OFAC) published in the Federal Register a notice publishing General License E and General License F issued under the Iranian transactions sanctions program on September 10, 2013. The General Licenses were only posted to the OFAC website when they were issued. General License E authorizes certain services in support of nongovernmental organizations’ activities in Iran, subject to certain limitations. General License F authorizes certain services…
On February 14, 2014, the Department of State published in the Federal Register a notice [Public Notice 8632] of temporary waivers of certain sanctions to allow for a discrete range of transactions related to the provision of satellite connectivity services to the Islamic Republic of Iran Broadcasting (IRIB). The US Government is issuing these waivers based on Iran’s commitment to ensure that harmful satellite interference does not emanate from its territory, and verification by the…
I. U.S. SanctionsAs reported in our Client Alert dated November 27, 2013, the United States and its partners in the P5+1 (i.e., China, France, Germany, Russian, and the United Kingdom) reached an initial understanding with Iran on November 24, 2013, outlined in a Joint Plan of Action (“JPOA”), targeted at gaining commitments from Iran on enrichment reductions, non-proliferation, and inspections of its nuclear program. In return, the P5+1 nations agreed to a gradual, step-by-step suspension…
Alex Lamy will serve as a moderator during the program “U.S. and EU Sanctions Implementation of the Iran Joint Plan of Action”. This is a non-CLE program proudly presented by ABA Section of International Law Export Controls and Economic Sanctions Committee in cooperation with Women in International Trade; Washington Foreign Law Society; Virginia State Bar International Practice Section; National Foreign Trade Council / USA*Engage; National Council on International Trade Development; and D.C. Bar International Law…
On January 30, 2014, the Office of Foreign Assets Control (OFAC) published in the Federal Register a notice of the publication of Guidance Relating to the Provision of Certain Temporary Sanctions Relief in Order to Implement the Joint Plan Of Action (JPOA) Reached on November 24, 2013, Between the P5+1 and the Islamic Republic of Iran (Guidance), issued on January 20, 2014. The Guidance sets out how, in furtherance of the U.S. Government’s (USG) commitments…