Next month, the Financial Action Task Force (“FATF”) will issue an updated public statement identifying jurisdictions that have strategic deficiencies…
Iran Sanctions-Lifting Continues to Be Frustrated
Even recent breakthroughs on the sanctions issue – upon closer examination – provide further evidence of the challenges for Iran…
It was a Bad Week for the Waked MLO
Lsat week, OFAC designated the Waked Money Laundering Organization, its leaders and associates, and 68 companies tied to it under…
Is this the USG’s New Messaging on Iran Sanctions?
This week, the 3rd Europe-Iran Forum took place in Zurich, Switzerland with close to 400 persons in attendance, including prominent…
Introducing Hizballah Financial Sanctions Regulations
On April 15, 2016, OFAC inaugurated the Hizballah Financial Sanctions Regulations (“HFSR”) located at 31 C.F.R. Part 566. These new…
High Stakes for Iran Sanctions-Lifting
Last week, U.S. Secretary of State John Kerry and Iran’s Foreign Minister Javad Zarif met twice to discuss ongoing problems…
New GAO Report Provides Much-Needed Accounting
Last week, the GAO released a report that provides some much-needed accounting as to the sums that OFAC and other…
Unresolved Questions on Offshore Dollar-Clearing
If the U.S. Treasury Department is unclear as to whether non-U.S. banks engaged in offshore dollar-clearing involving Iran would implicate…
Is Iran Sanctions-Lifting Going Worse Than Expected?
It is clear by now that Iran is experiencing grave difficulties receiving practical value from the sanctions-lifting provided under the…
Iran Sanctions Roadshow, 2016 Tour
The Financial Times reports that U.S. officials are on tour explaining the new rules of the road when it comes…