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…
How I Became a “Volunteer Fed”
You may remember a minor uproar several months ago surrounding a newly imposed and quickly retracted policy at the University…
Those Who Cannot Remember the Past Are Condemned to Repeat It: Iran Edition
As the deadline for a comprehensive agreement approaches, many companies are salivating at the prospect of a sanctions-free Iran. With…
Sanctions Relief on the Table in Vienna, Part 2
Besides the pace at which sanctions are relieved as part of a Joint Comprehensive Plan of Action (“JCPOA”) between the…
Is DOJ Overreaching in Texas IEEPA Case?
Earlier this week, Taiwanese citizen Kunlin Hsieh pleaded guilty to violations of the International Emergency Economic Powers Act (“IEEPA”) for…
Iran, U.S. Trade Warnings Over Mahan’s New Airbuses
In the latest installment of the Mahan Air/Al-Naser Airlines saga, officials from both the U.S. and Iran have begun exchanging…
Exxon’s “Lobbying” Drama Shows Iran Still Too Hot to Touch
Last week Bloomberg and several other media outlets began breathlessly reporting on oil giant Exxon Mobil foray into Iran sanctions…
Is There Sanctions Liability Lurking in the Dubai Airport?
Margaret Ververis, the Senior Associate at Ferrari & Associates, recently returned from trip to Dubai and was nice enough to…
OFAC/BIS Drop the Hammer on Al-Naser Airlines
About a week and a half ago, I flagged Mahan Air’s apparently successful effort to acquire Western commercial aircraft using…
Iran Walks Back “American Oil Delegation” Claim
Last week I wrote a piece on the dangerous new condition known as Iranian Agreement Derangement Syndrome (IADS) in which…