The JCPOA’s “Snapback Sanctions”: A Victory for the United States
One of the most curious critiques of the Joint Comprehensive Plan of Action (“JCPOA”) agreed to by the U.S., other…
Iran’s Phantom PATRIOT Act 311 Designation
On July 23, the Financial Crimes Enforcement Network (“FinCEN”) issued a Final Rule pursuant to § 311 of the USA…
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…
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…
The Shaky Foundations of an Iran Deal Counter-Argument
One of the central critiques of the recently agreed-to Joint Comprehensive Plan of Action (“JCPOA”) is that under the…
The Biggest Question Mark for U.S. Businesses in the Iran Deal
The long awaited nuclear deal between the P5+1 and Iran, née “The Joint Comprehensive Plan of Action” (“JCPOA”), is upon…