So You Want to Reside in Iran?

If a U.S. person is interested in moving to Iran on a permanent basis, can that U.S. person open a bank account there without falling afoul of U.S. sanctions? Surprisingly, the answer is “perhaps, yes,” according to recent interpretive guidance provided by the United...

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...

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...