The Trump administration reportedly came close to de-certifying Iran’s compliance with the JCPOA. If it chooses to do so in the future, how will President Trump re-impose sanctions unilaterally on Iran?
Admittedly, I'm late to the party on this, but as you likely already know the D.C. Circuit has issued its decision in the Epsilon Electronics v. U.S. Department of the Treasury litigation that I have spent so much time writing on over the past two years. There is a...
The Senate has taken a big step towards reclaiming Congress’ prerogatives over the application of U.S. economic sanctions, including, in particular, the decision to lift and/or ease U.S. sanctions on a target State.
On June 8, 2017, OFAC announced a settlement with the American Honda Finance Corporation for apparent violations of the CACR. Does OFAC’s application of the Enforcement Guidelines compute, though?
The DC Circuit Court of Appeals engaged in an interpretive exercise as to the scope of the Iran export ban in Epsilon v. OFAC. The Court’s holding has important implications for US exporters.