Tyler Cullis December 22, 2015 Congress Sets Its Sights on Iran Keen on limiting the impact of sanctions relief for Iran’s Revolutionary Guards Corps (“IRGC”), as well as any broader outreach…
Tyler Cullis October 26, 2015 The Implications of an FTO Designation for the IRGC In late September, Senator Ted Cruz (R-TX) introduced the IRGC Terrorist Designation Act, S.2094, which would express the sense of…
Tyler Cullis August 26, 2015 Can’t Stop Won’t Stop: Congress on Iran Sanctions You can’t help but be curious as to how far a little bit of sanctions knowledge would go for some…
Samuel Cutler August 24, 2015 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…
Samuel Cutler July 30, 2015 The Greatest Weapon Against the IRGC: American Business? One of the key misconceptions you often encounter about the consequences of sanctions violations is that a monetary penalty can…
Samuel Cutler May 16, 2015 Potential Risks in Post-deal Iran Investment For companies considering reentry into the Iranian market, there are a number of concerns that should impact the timing and…
Erich Ferrari February 11, 2010 Undeterred by Snowstorm, OFAC Designates Iranians I was quite surprised to find out that the United States Department of the Treasury Office of Foreign Assets Control…