On December 31, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) inaugurated the much-anticipated ‘Cyber-Related…
Negotiating the Future of Iran Sanctions, the White House Stumbles
This past Wednesday, the Wall Street Journal reported that the United States was set to impose additional designations on certain…
2015 Year-in-Review: New Developments in U.S. Sanctions
2015 brought new opportunities and new challenges in the sanctions world. The most interesting developments, however, start and end with…
Are US Companies at Peak Interest in Iran?
While U.S. law continues to prohibit most activities involving Iran, U.S. companies will remain even more put-off by the perceived…
The Repercussions of Iran’s Ballistic Missile Tests
Controversy is stirring over Iran’s conduct of two ballistic-missile tests since the July nuclear agreement – both of which are…
Congress Sets Its Sights on Iran
Keen on limiting the impact of sanctions relief for Iran’s Revolutionary Guards Corps (“IRGC”), as well as any broader outreach…
OFAC Continues to Target La Oficina de Envigado
Since June 26, 2014, OFAC has taken significant steps to disrupt the financing of La Oficina de Envigado, a Colombian-based…
Trouble Ahead for JCPOA Implementation?
Could we be seeing the first complications of JCPOA implementation? Last week, the House passed H.R. 158, which included amongst…
Kirsan Ilyumzhinov: The Case of the (Ir)relevant Facts
No one expects OFAC to provide a detailed basis for its decision to designate certain individuals and entities under its…
Update on Timeline for Implementation Day
The U.S. Department of the Treasury’s Office of Foreign Assets Control is scheduled to release detailed guidance relating to the…