You Talking to Me? The ITSR, Iranians, and Ordinary Residency
Just because you are a citizen of Iran does not mean that the Iranian Transactions and Sanctions Regulations (“ITSR”) prohibit…
Ummm What? Dastranj v. Dehghan
On August 17, 2017, the United States District Court for the District of Maryland issued a memorandum opinion granting in…
Not Exactly a Line in the Sand: The D.C. Circuit and Attempt Liability Under the ITSR
Admittedly, I’m late to the party on this, but as you likely already know the D.C. Circuit has issued its…
Better do Your Due Diligence on Doing Due Diligence
Ever since the Joint Plan of Action–the framework to what eventually would become the Joint Comprehensive Plan of Action–was signed…
Paradoxes of the JCPOA Sanctions Relief
It’s only been a few weeks since the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)…
Shipping to Afghanistan? How is your OFAC Compliance Program Looking?
Over the past year or so, we've seen the United States Department of the Treasury's Office of Foreign Assets Control…
In Defense of the “Inventory Exception”: Epsilon Electronics Goes All In
Readers of SanctionLaw.com may recall an article that I wrote at the beginning of the year concerning the lawsuit brought…
Another U.S. Subsidiary of a Foreign Parent Company Leads to OFAC Penalty
There is always a lot made of U.S. companies being subjected to liability for sanctions violations for the actions of…
Iranian Tennis Referee Banned From US Open; Not Sanctions’ Fault?
On Wednesday the New York Times ran a story entitled “Sanctions Against Iran Mean a Tennis Referee Can’t Work at…
Another Houston Company Settles With OFAC
Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with EGL, Inc.,…