Sanctions

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In its continuing effort to tighten economic sanctions on Iran, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned five United Arab Emirates (UAE)-based companies that facilitate the Iranian regime’s petroleum and petrochemical sales. According to OFAC, these companies in 2019 “collectively purchased hundreds of thousands of metric tons of petroleum…

UPDATED: April 6, 2020 – Major operational changes continue at trade-related U.S. government agencies and courts  due to personnel and public safety concerns over the COVID-19 outbreak in the United States. Below is currently available information on their status. Overall, the Office of Personnel Management has announced that as of March 16, 2020, and until…

In his State of the Union address to Congress last night, President Donald Trump spoke of the “great American comeback” and claimed that “[t]he years of economic decay are over.  The days of our country being used, taken advantage of, and even scorned by other nations are long behind us.” His prepared speech focused briefly…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned eight individuals and one entity in response to Russia’s continued aggression toward Ukraine and attempted occupation of Crimea, which the United States continues to view as an illegitimate annexation since it occurred in 2014. OFAC has designated and placed on the Specially…

On January 10, 2020, President Donald Trump issued “Executive Order on Imposing Sanctions with Respect to Additional Sectors of Iran,” implementing further sanctions on Iran and blocking the assets and property of additional senior Iranian government officials. The executive order authorizes economic sanctions on entities operating in the construction, mining, manufacturing or textiles sectors of…

On December 13, 2019, the U.S. Department of Justice (DOJ) released a revised policy for companies regarding voluntary self-disclosures of export control and sanctions violations. The revised policy was effective on the date of its release and will be formally incorporated into the Justice Manual. In releasing the revised Voluntary Self-Disclosure Policy (VSD Policy),…

On the 40th anniversary of the Iranian takeover of the U.S. Embassy in Tehran and the hostage-taking of more than 50 U.S. diplomats and officials, the United States announced November 4, 2019, a further tightening of sanctions on Iran. In its statement supporting these sanctions, the White House explained, “The Iranian regime continues to…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced a new “humanitarian mechanism” to ensure transparency in humanitarian trade with Iran. According to OFAC, this mechanism “will help the international community perform enhanced due diligence on humanitarian trade to ensure that funds associated with permissible trade in support of the Iranian…

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a long-awaited final rule prohibiting the opening or maintaining of correspondent accounts in the United States for, or on behalf of, Iranian financial institutions, and the use of foreign financial institutions’ correspondent accounts at covered U.S. financial institutions to process transactions involving Iranian…

Merely nine days after implementing sanctions on Turkey for its military action in northeast Syria (see Trump and Trade Update of October 15, 2019), President Donald Trump announced that he was lifting those sanctions due to the continuing ceasefire along the border. The president stated that Turkey would be halting its offensive and make…