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…
Will Boeing and Iran Air Rekindle Their Romance?
October 18, 2015 marked “Adoption Day” for the Joint Comprehensive Plan of Action (“JCPOA”), the day on which the P5+1…
Guidance on Iran Sanctions Relief is Coming Sooner Than Later
I’ve been getting a lot of questions recently as to when we can expect OFAC to start issuing guidance related…
OFAC Issues Comprehensive JCPOA Guidance Stating That Nothing Has Changed
At the heart of the Office of Foreign Assets Control’s (“OFAC”) implementation of the Joint Comprehensive Plan of Action (“JCPOA”)…
Adoption Day Arrives, Iran Nuclear Agreement Now Effective
This past Sunday, the nuclear agreement between the U.S., other major world powers, and Iran (also known as the Joint…
Defending the Legality of the JCPOA’s Foreign Sub Provision
It seems every week brings a new controversy over the U.S.-Iran nuclear accord. Last week, Fox News reported that certain…
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…
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…
Wild Claims About the Anis Nacacche Sanctions Designation Removal
Yesterday, the Wall Street Journal ran a piece by the nephew of Shapour Bakhtiar, the last prime minister under 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…