De-Risking in Global Financial Institutions
Previously, I have written about how the major enforcement actions against global financial institutions for Iran sanctions-related violations should not…
Defending the Legality of the JCPOA’s Foreign Sub Provision
It seems every week brings a new controversy over the U.S.-Iran nuclear accord. Last week, Fox News reported that certain…
Szubin on Snapback Sanctions
In a previous post, I discussed how critics of the nuclear deal were misinterpreting the snapback sanctions provision in the…
Senate Fails the Belichick Test, Won’t Confirm Adam Szubin
It has been almost three months since President Obama formally nominated Adam Szubin as Undersecretary for Terrorism and Financial Intelligence…
New Sanctions Coming for…..Venezuela?
Over a year ago, I wrote a couple of blog postings regarding the growing concerns of the U.S. Government surrounding…