The Director of the U.S. Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) made two sanctions-related determinations on…
Sanctions Compliance: A Unique Approach for Conglomerates
The U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) January 2022 settlement agreement with Sojitz (Hong Kong)…
Medical Supply and Agricultural Transaction Considerations for Russia/Ukraine: U.S. Sanctions and Export Controls
U.S. economic sanctions programs and export controls generally have a soft spot for transactions related to the supply of agricultural…
Benchmarking Sanctions Compliance Programs with the Help of Prior OFAC Enforcement Actions
When creating or enhancing a U.S. economic sanctions compliance program, businesses will typically refer to certain published guidance from the…
The Russians are Coming (Maybe)! Risk Mitigation Tips for Potential U.S. Economic Sanctions and Export Controls
Tune into your favorite news network these days and there’s a lot of speculation on how the United States and…
Why did Airbus wait until Implementation Day for the Iran Air Deal?
Why did Airbus, a European aircraft manufacturer, have to wait until the lifting of certain U.S. sanctions targeting Iran to…
Will Boeing and Iran Air Rekindle Their Romance?
October 18, 2015 marked “Adoption Day” for the Joint Comprehensive Plan of Action (“JCPOA”), the day on which the P5+1…