Why Did the USG Not Provide Iran 400 Million USD?

Last week, I pointed out that those arguing that the U.S.’s $400 million cash payment to Iran was in violation of U.S. sanctions had failed to appreciate the fact that U.S. sanctions programs contained not just sanctions prohibitions, but also exemptions and license...

State Dept. Commits Serial Mistake on Iran Sanctions

Following reports that the U.S. government transferred $4,000,000 in cash to the Government of Iran in its settlement of outstanding claims being litigated at the U.S.-Iran Claims Tribunal in The Hague, an exchange took place at the U.S. State Department’s press...

OFAC Issues General License J to the ITSR

On July 29, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License J to the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. Part 560, authorizing the re-exportation by non-U.S. persons of certain...
PIJIC Blocked, But Not Identified

PIJIC Blocked, But Not Identified

As subscribers to the paid portion of SanctionLaw already know, we’ve obtained a lot of information pursuant to Freedom of Information Act (FOIA) requests submitted to the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC)...

Treasury Designates al-Qaida Members Located in Iran

Last week, the United States Department of the Treasury announced the designation of three senior al-Qaida members located in Iran – Faisal Jassim Mohammed al-Amri al-Khalidi, Yisra Muhammad Ibrahim Bayumi, and Abu Bakr Muhammad Ghumayn – for acting for or on behalf...

OFAC Rescinds Mohamed Daki’s Designation

What a long, strange trip it can be for SDNs. On June 30, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the de-listing of Mohamed Daki, a Moroccan national formerly based in Europe. Daki’s de-listing followed more than a...