Erich Ferrari August 23, 2018 They’re Ba-ack….JCPOA Withdrawal Nearing Completion with E.O. 13846 There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from…
Tyler Cullis May 19, 2017 Have We Entered a New Phase of Iran Sanctions? Some allege that the Trump administration is taking a more punitive approach towards Tehran.
Tyler Cullis March 6, 2017 Is There a “Policy Gap” in IRGC Sanctions? Is there a "policy gap" regarding U.S. sanctions targeting the IRGC and its designated agents or affiliates? Proposed legislation seems…
Tyler Cullis February 22, 2017 So You Want to Reside in Iran? If a U.S. person is interested in moving to Iran on a permanent basis, can that U.S. person open a…
Tyler Cullis December 27, 2016 OFAC Amends ITSR, Permits U.S. Person Training On December 23, 2016, OFAC amended the ITSR – the first substantive amendment to the regulations since the advent of…
Erich Ferrari July 7, 2016 Better do Your Due Diligence on Doing Due Diligence Ever since the Joint Plan of Action–the framework to what eventually would become the Joint Comprehensive Plan of Action–was signed…
Tyler Cullis April 11, 2016 Is Iran Sanctions-Lifting Going Worse Than Expected? It is clear by now that Iran is experiencing grave difficulties receiving practical value from the sanctions-lifting provided under the…
Erich Ferrari March 28, 2016 OFAC Targets UK Businesses, Businessmen for Support to Mahan Air Lost in the all of the excitement last week over General License I issued by the United States Department of…
Erich Ferrari February 19, 2016 Paradoxes of the JCPOA Sanctions Relief It’s only been a few weeks since the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)…
Tyler Cullis January 26, 2016 Where OFAC’s Iran Guidance Falls Short Not a hopeful sign for an Iran seeking to re-integrate with the global financial system.