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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…

In a Federal Register notice, the Department of Commerce’s Bureau of Industry and Security (BIS) has announced that effective September 22, 2020, it is adding 47 entities to its Entity List after determining these companies and persons to be acting contrary to the national security or foreign policy interests of the United States. The entities…

On September 3, 2020, the Department of State and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned numerous entities and persons for their reported involvement with the petroleum or petroleum sector of Iran. According to a press statement from Secretary of State Michael Pompeo,  the targeted entities and persons have “continued…

On August 26, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was adding 24 Chinese companies to the Entity List for their role in helping the Chinese military construct and militarize the internationally condemned artificial islands in the South China Sea. “The United States, China’s neighbors, and the international…

The Department of Commerce’s Bureau of Industry and Security (BIS) and the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against several persons and entities determined to be supporting Iran’s Mahan Air in violation of U.S. sanctions toward Iran. According to both agencies, the involved companies have provided key parts and logistics services…

On June 25, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that its recent designations to the Specially Designated Nationals and Blocked Entities (SDN) List targeted Iran’s steel, aluminum, copper, and iron sectors. OFAC designated eight entities operating in the Iranian metals sector including companies from Iran, the United…

On June 8, 2020, the State Department announced sanctions against the Islamic Republic of Iran Shipping Lines (IRISL) and its Shanghai-based subsidiary, E-Sail Shipping Company Ltd (E-Sail) pursuant to Executive Order 13382, which targets weapons of mass destruction (WMD) proliferators and supporters.  In a press statement, Secretary of State Mike Pompeo noted that,…

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued four new Frequently Asked Questions​​ (FAQs) related to Executive Order (E.O.) 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran.”  The FAQs address the manufacture of medicines, medical equipment and sanitation products in Iran, the scope of sectors targeted…

On May 27, 2020, Secretary of State Mike Pompeo announced that the United States was ending the sanctions waiver pertaining to the remaining nuclear projects in Iran covered by the Joint Comprehensive Plan of Action (JCPOA) – the Arak reactor modernization conversion, the provision of enriched uranium for the Tehran Research Reactor, and the export…

On May 14, 2020, the U.S. Departments of State and Treasury and the U.S. Coast Guard issued a global advisory to alert the maritime industry and those active in the energy and metals sectors to deceptive shipping practices used to evade U.S. economic sanctions.  It is intended to provide exporters, shippers and others utilizing the…