SDGT Removal Highlights EO 13224 Designation Responsibilities
Generally speaking, when an email from the U.S. Department of the Treasury referencing a “Counter Terrorism Designation Removal” pops up…
Don’t Overlook the Civil/Criminal Liability (Potentially) Lurking in the JCPOA’s Foreign Sub Provision
As I've written about previously, the license for foreign subsidiaries of U.S. companies described in the Joint Comprehensive Plan of…
How Preserving the Sanctions Architecture Informed Iran Sanctions Relief
In designing the Joint Plan of Action, which set the stage for the U.S.-Iran negotiations that would culminate in the…
GAO Dives Into the FTO Designation Process
Last week the Government Accountability Office (“GAO”) published an interesting report on the Foreign Terrorist Organization (“FTO”) designation process. It’s…
![You’ve Been Listed Due to [REDACTED]: Designation Evidence and Sanctions Legitimacy](https://sanctionlaw.com/wp-content/uploads/2015/06/download-1-e1434393948561.jpeg)
You’ve Been Listed Due to [REDACTED]: Designation Evidence and Sanctions Legitimacy
Last week, OFAC designated three Lebanese businessmen described as Hezbollah “facilitators” and (some) of their affiliated companies. On Friday, one…
An Exercise in Redundant Sanctions: HR 2297
Earlier today, the House passed HR 2297 a.k.a. the Hezbollah International Financing Prevention Act, by a vote of 423-0 vote.…
Mahan Air Strikes Again
Iran’s Specially Designated Global Terrorist (“SDGT”) listed airline Mahan Air has apparently succeeded in another sanctions-busting coup. Yesterday, Transportation…