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…
IP Services Under The ITSR: A Broad Exception?
If you’ve ever heard me speak at a conference or seminar on U.S. sanctions, then you’ll know one of my…
New Venezuela Sanctions–Sectoral Sanctions Without the Sectors?
Perhaps lost amidst the weekend’s news of Hurricane Harvey, Seb Gorka resigning, and Joe Arpaio being pardoned, was the announcement…
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…
Websites for Marketing of Dietary Supplements to Iran Exempt Under the Information or Informational Materials Exemption
As readers of this blog may know, dietary supplements are generally authorized for export to Iran, pursuant to the general…
CASE STUDY: Sale of Shares in an SDN Entity
Recently, we had an opportunity to successfully represent a private individual who held assets in an Iranian entity obtain a…
More NDAA 1245 Waivers Issued By U.S. Government
On Friday, the United States announced that it had extended sanctions waivers to ten (10) European Nations and Japan due…
Is the De Minimis Rule Still in the ITSR?
There have recently been a number of sources reporting that there is no longer a de minimus rule contained in…
Iranian Tennis Referee Banned From US Open; Not Sanctions’ Fault?
On Wednesday the New York Times ran a story entitled “Sanctions Against Iran Mean a Tennis Referee Can’t Work at…
Burma…Going….Going…But Not Yet Gone
Last week, President Obama, in light of the expiration of the Burmese Freedom and Democracy Act’s (BFDA) import ban issued…