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US – OFAC designates Iranian entities and banks as Specially Designated Nationals and FinCEN issues advisory on Iran’s “Illicit and Malign” activities and attempts to exploit financial systems

By 4 Mins Read

On October 16, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated certain Iranian entities and banks as Specially Designated Nationals (“SDNs”) pursuant to Executive Order (“EO”) 13224, which targets terrorists and those providing support to terrorism. A full list of those entities designated as part of this action is available here.  US Persons (i.e., entities organized under US laws and their non-US branches; parties physically located in the United States; US citizens and permanent resident aliens wherever located or employed) are prohibited from dealing directly or indirectly with SDNs.  Under the Iranian Transactions and Sanctions Regulations (“ITSR”), non-US entities owned or controlled by US Persons are also prohibited from dealing with SDNs that are located or based in Iran (regardless of their reason for designation) or owned or controlled by the Government of Iran (regardless of where they are located).

US – BIS amends Entity List

By 1 Min Read

On September 26, 2018, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule [Docket No. 180910826-8826-01] that amends the Export Administration Regulations (EAR) by adding fourteen entities to the Entity List. These fourteen entities have been determined by the US Government to be acting contrary to the national security or foreign policy interests of the United States and will be listed on the Entity List under the destinations of Belarus, Iran, Russia, and Singapore.

US – OFAC revokes general licenses for parties subject to US jurisdiction to engage in Iran-related business and formally establishes wind-down periods

By 3 Mins Read

On June 27, 2018, the US Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it was amending the Iranian Transactions and Sanctions Regulations (ITSR) to revoke or narrow certain general licenses issued as part of the US sanctions relief implementing the Joint Comprehensive Plan of Action (JCPOA), replacing them with more limited wind-down authorizations. Importantly, OFAC stated that these actions were in furtherance of President Trump’s May 8, 2018 decision to withdraw the United States from the JCPOA. As discussed in our earlier blog post, OFAC had previously announced its intent to replace these general licenses with more limited wind-down authorizations in public guidance issued on May 8, 2018, which OFAC updated in connection with these changes. OFAC’s amendments to the ITSR were published in the Federal Register on June 28, 2018.

Client Alert – United States Withdraws from Joint Comprehensive Plan of Action

By 2 Mins Read

Executive Summary Effective May 8, 2018, the US Government withdrew from the Joint Comprehensive Plan of Action (“JCPOA”). The US Government will re-instate the sanctions that were lifted or waived following the implementation of the JCPOA. This action has a greater impact on non-US persons because most of the lifted or waived sanctions were secondary sanctions targeting activities of non-US companies occurring outside of US jurisdiction. The sanctions will be re-instated on August 7, 2018,…

Imposition of nonproliferation measures against foreign persons, including a ban on U.S. government procurement

By 2 Mins Read

On May 10, 2018, the Department of State published in the Federal Register a notice [Public Notice: 10407] that a determination has been made that a number of foreign persons have engaged in activities that warrant the imposition of measures pursuant to Section 3 of the Iran, North Korea, and Syria Nonproliferation Act (the “Act”; Pub. L. 109–353).

US – United States withdraws from Joint Comprehensive Plan of Action

By 7 Mins Read

On May 8, 2018, President Trump announced that the United States will be withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”), culminating months of uncertainty around the fate of the Iran nuclear deal. The announcement came ahead of a May 12 deadline for the renewal of a key sanctions waiver.  As described here, the last sanctions waiver occurred on January 12, 2018 amidst statements by President Trump that the waiver would be the last unless what President Trump considered “flaws” in the deal were fixed.  In his May 8 speech, President Trump announced that the United States would re-impose nuclear sanctions against Iran. 

US to include digital currency addresses on list of sanctioned parties

By 3 Mins Read

The US Government is considering adding digital currency addresses affiliated with individuals and entities identified to the List of Specially Designated Nationals and Blocked Persons (“SDN List”). This would put US persons on notice that doing business with those digital addresses may be prohibited, increasing compliance considerations for businesses delving into the world of virtual currency.