OFAC’s most recent settlement agreement reflects its increasingly broad interpretation of IEEPA’s jurisdictional scope and evidences its willingness to penalize non-U.S. companies for violations of U.S. sanctions regulations.
I spend a lot of time online. This is due, in part, to the fact that one of my favorite past times is going on Twitter and hearing the endless roar of non-sanctions practitioners (a.k.a. lay persons) scream about who should be on the OFAC SDN List, and complain about...
It is apparent that ExxonMobil dealt in the services of a blocked person. OFAC could have ended the argument there. Instead, it pressed forward a curious argument that undermines its case.
On July 28, 2017, OFAC designated four Iranian entities owned or controlled by Shahid Hemmat Industrial Group , an Iranian entity alleged to be “central to Iran’s ballistic missile program” and designated in the Annex to Executive Order 13382.
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?