On September 29, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of international companies for facilitating the sale of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum products to South and East Asia. OFAC targeted the network, which includes a myriad of front companies in

On September 23, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Iran General License (GL) D-2 which authorizes the export, reexport by U.S. persons to Iran of certain services, software and hardware incident to communication. The purpose of the revised GL is to bring this OFAC guidance on

On June 17, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three general licenses related to the sanctions programs of Iran (General License N), Syria (General License 21) and Venezuela (General License 39), “Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19)

On June 15, 2021, the United States and European Union (EU) issued a joint Summit Statement trumpeting a “renewed transatlantic partnership” at the conclusion of President Joseph Biden’s first trip abroad as president.  The statement establishes a Joint Transatlantic Agenda “for the post-pandemic era, and … regular dialogue to take stock of progress.”  The leaders

On January 15, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule implementing further provisions of the Export Control Reform Act of 2018 by: (i) imposing additional export license requirements under the Export Administration Regulations (EAR) in connection with certain military-intelligence end uses and end users; (ii) clarifying

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State have announced further sanctions toward Iran by designating and placing on the Specially Designated Nationals (SDN) List a China-based supplier of graphite electrodes, 12 Iranian producers of steel and other metals products, three foreign-based sales agents of a major

The Office of Foreign Assets Control (OFAC) has revised Iran-related frequently asked questions (FAQs) to clarify that the sanctions authorized against the Iranian construction, mining, manufacturing and textiles sectors, among others, will not target Iranian manufacturers of medicines, medical devices, or products used for sanitation or hygiene or as personal protective equipment, solely for use

On November 25, 2020, the State Department issued a Federal Register Notice announcing the imposition of nonproliferation measures against certain Chinese and Russian entities for the transfer of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the

On October 8, 2020, the Departments of State and the Treasury announced sanctions on numerous Iranian financial institutions. The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned eighteen major Iranian banks. Secretary of the Treasury Steven Mnuchin stated that the sanctions “reflect our commitment to stop illicit access to U.S.

On September 19, 2020, the United States announced that virtually all United Nations (UN) sanctions on Iran were being re-imposed. President Donald Trump and Secretary of State Mike Pompeo have taken the position that the United States can trigger the “snapback” provisions of UN sanctions under UN Security Council resolution 2231 pursuant to the Joint