Erich Ferrari December 13, 2016 Is Epsilon Electronics the Donald J. Trump of OFAC Enforcement Cases? I’m going to have to pick up a new hobby once the United States Court of Appeals for the District…
Tyler Cullis December 12, 2016 Boeing Enters into Contract with Iran Air In a landmark deal, Boeing finalized its contract with Iran Air for the sale of 80 civil passenger aircraft --…
Tyler Cullis December 8, 2016 UNSCR 2321 Opens Door for Stronger and More Extensive U.S. Enforcement of DPRK Sanctions The new Security Council resolution has opened the door for the U.S. to utilize its existing sanctions authorities and bring…
Tyler Cullis November 25, 2016 OFAC Licenses Airbus’ Sale of Aircraft to Iran OFAC reportedly issued its final batch of specific licenses to Airbus for the export or re-export of civil passenger aircraft…
Tyler Cullis November 21, 2016 The Real Threat to Iran’s Boeing & Airbus Deals Last week, the U.S. House of Representatives passed a bill that could effectively bar the export of passenger aircraft to…
Tyler Cullis November 14, 2016 Escalated Risk Commercially Engaging Iran Post-Trump Commercial engagement with Iran involves multiple levels of risk. With the election of Donald Trump, the legal risk inherent in…
Tyler Cullis November 6, 2016 Mixed Messages: Is the Obama Administration on the Same Page Regarding JCPOA Implementation? Part II The State Department adds a correction to Secretary Kerry's remarks on the due diligence obligations of financial institutions engaged in…
Tyler Cullis November 2, 2016 Mixed Messages: Is the Obama Administration on the Same Page Regarding JCPOA Implementation? Secretary Kerry recently stated that banks need only conduct "normal due diligence" for Iran-related transactions. If true, that'd be news…
Erich Ferrari November 1, 2016 Fright Night: OFAC, the Iranian Transactions and Sanctions Regulations, and the Dangers of Websites Halloween was yesterday, but there was still something scary on my desk when I walked into the office this morning:…
Tyler Cullis November 1, 2016 OFAC Issues Guidance on Publishing Activities How do U.S. newspapers publish articles authored by Iran's Foreign Minister? OFAC's newly-issued interpretive guidance on certain publishing activities begins…