The Question of Enforcements of Pre-Implementation Violations
In the wake of the nuclear agreement between the United States, other major world powers, and Iran (also known as…
Iran’s Prized Collection of Western Art Might Be Coming to America, but Don’t Count on It
Word is getting out that Iran is host to one of the most prized collections of Western art outside of…
The Return of the General License: Authorizing the Importation of Iranian-Origin Carpets and Foodstuffs
As is clear by now, the nuclear agreement between the United States, other major world powers, and Iran will herald…
Compliance for Trade Brokers under the ITSR: When is an OFAC License Required?
The Iranian Transactions and Sanctions Regulations ("ITSR") administered by the United States Department of the Treasury's Office of Foreign Assets…
Count Me a Skeptic
On October 10, Press TV reported that Iranians are now able to make direct purchases from Amazon and eBay “international…
More Sanctions Trouble at Standard Chartered
What is going on at Standard Chartered? Following significant penalties from U.S. authorities in 2012 and in 2014 alike, as…
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…
Could the U.S. Trade Embargo with Iran Be With Us Forever…?
According to remarks by Secretary of State John in New York yesterday afternoon, the answer is: yes. Speaking at a…
OFAC Reminds Us of the Risks in the JCPOA’s Foreign Subsidiary Provision
Last week, the Office of Foreign Assets Control (“OFAC”) provided everyone with an important reminder that the foreign subsidiary license…
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…