IRGC Sanctions: A (Brief) History

Reports indicate that the Trump administration is considering the promulgation of an Executive Order that would direct the Secretary of State to designate the Islamic Revolutionary Guard Corps (IRGC) – a branch of Iran’s armed forces – a Foreign Terrorist Organization...

Is It a New Day in Iran Sanctions?

On February 3, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) added 13 individuals and 12 entities to its List of Specially Designated Nationals and Blocked Persons (SDN List) for either engaging in activities supportive of Iran’s...
IEEPA: So Easy Even a Caveman Can Understand It

IEEPA: So Easy Even a Caveman Can Understand It

Here goes my sour grapes post. There have been a number of motions to dismiss filed by defendants in criminal prosecutions for violations of the International Emergency Economic Powers Act (IEEPA) arising from conduct prohibited by the Iranian Transactions and...

Did Rex Tillerson Violate the ITSR? Likely Not.

Rex Tillerson, President-elect Trump’s nominee to lead the U.S. Department of State, will sit for his nomination hearing this morning. It has long been expected that Tillerson – former CEO at Exxon Mobil – will face tough questioning regarding Exxon’s ties with...

OFAC Amends ITSR, Permits U.S. Person Training

On December 23, 2016, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. Part 560 – the first substantive amendment to the regulations since the advent of...

OFAC Issues North Korea-Related General License 1-A

It is an elemental point but nonetheless one worthy of reminder: as OFAC can authorize certain otherwise prohibited transactions via general or specific license, so may OFAC rescind those authorizations and reinstate the prohibitions. Those following the North Korea...

Does ISA Extension Violate the JCPOA?

This weekend, Iran’s Foreign Minister Mohammad Javad Zarif sent a letter to the European Union’s Foreign Policy Chief Federica Mogherini requesting a meeting of the JCPOA’s Joint Commission to discuss the Iran Sanctions Extension Act, which was recently-enacted into...

OFAC Amends Iran FAQs, Issues General License J-1

Acting consistent with its pledge to update its Iran-related Frequently Asked Questions (FAQs) as new questions arise, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued further revisions to its FAQs relating to the U.S....