The Biggest Question Mark for U.S. Businesses in the Iran Deal
The long awaited nuclear deal between the P5+1 and Iran, née “The Joint Comprehensive Plan of Action” (“JCPOA”), is upon…
The Beauty of TRA Section 504
Can a sanctions provision be so well constructed and creative that in some respects it can be considered… beautiful? It’s…
OFAC Updates the IFSR, Includes Definitions
Earlier this week, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended Part 561 of…
The Iran-TRA’s Secondary Sanctions Trap
I have been getting a lot of questions lately about the Iran Threat Reduction and Syrian Human Rights Act of…