I Been Bad, and I Don’t Care: NYT Edition
It’s no secret that we are in the midst of a bout of exuberance over the opening of the Iranian…
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…
Szubin on Snapback Sanctions
In a previous post, I discussed how critics of the nuclear deal were misinterpreting the snapback sanctions provision in the…
Iran’s Phantom PATRIOT Act 311 Designation
On July 23, the Financial Crimes Enforcement Network (“FinCEN”) issued a Final Rule pursuant to § 311 of the USA…
Iran Deal: Will Foreign Subsidiaries of US Parents Get General License Authorization?
In a recent post, Sam discussed the open question of whether – pursuant to § 5.1.2 of Annex II of…
The Impact of an OFAC Designation on the Bottom Line
There might be no better indicator of the impact of an OFAC SDN designation than the press release just put…
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 Publishes the Iranian Human Rights Abuses Sanctions Regulations
Last September, President Obama issued Executive Order 13553 which called for the identification and targeting for sanctions of parties engaged…
OFAC Hits Balli Group PLC and Balli Aviation With A Massive Penalty
I know I’m starting to sound like a broken record here, but the United States Department of the Treasury Office…
One Fish, Two Fish, Big Fish, Small Fish?
Ladies and gentlemen of my readership…….Sorry about that I just wrapped up a jury trial in Houston and Im still…