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On June 7, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Iran’s largest petrochemical holding group, Persian Gulf Petrochemical Industries Company (PGPIC). In addition to PGPIC, OFAC placed 39 PGPIC subsidiaries and foreign-based sales agents on its Specially Designated Nationals (SDN) List. According to OFAC, PGPIC was sanctioned for having…

President Donald Trump has announced further action against Iran by imposing sanctions on its iron, steel, aluminum and copper sectors, the country’s largest non-petroleum-related sources of export revenue. In an executive order, the president implemented blocking sanctions on any person determined by the secretary of the Treasury, in consultation with the secretary of State,…

On April 9, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $639,023,750 settlement with Standard Chartered Bank (SCB), a UK-based financial institution, over potential civil liability related to alleged violations of the now-repealed U.S. economic sanctions on Burma and Sudan and the continuing sanctions on Cuba, Iran and…

In recent weeks the U.S. government has taken two notable steps to further sanction and pressure the Islamic Republic of Iran. On March 26, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action against 25 individuals and entities by placing them on the Specially Designated Nationals (SDN) List. This…

In his second State of the Union address to Congress, President Donald Trump noted that he campaigned on several core promises, including “to defend American jobs and demand fair trade for American workers.” He argued that his administration has “moved with urgency and historic speed to confront problems neglected by leaders of both parties over…

The U.S. Department of Justice (DOJ) unsealed two separate indictments on Monday, January 28, 2019, charging Chinese telecommunications giant Huawei with 23 counts of criminal activity. In the Eastern District of New York (EDNY), a 13-count indictment was released charging four defendants affiliated with Huawei. In the indictment, Huawei Technologies Co., Ltd., Huawei Device USA Inc., Skycom Tech Co. Ltd. (Skycom) and Huawei’s Chief Financial Officer Wanzhou Meng were charged with a variety of crimes, including bank fraud, conspiracy to commit bank fraud, wire fraud and violations of the International Emergency Economic Powers Act (IEEPA), which serves as the statutory authority for the Iranian Transactions Sanctions Regulations (ITSR). In the Western District of Washington, the second unsealed indictment charges Huawei Device Co., Ltd. and Huawei Device USA, Inc. with 10 counts of theft of trade secrets conspiracy, attempted theft of trade secrets, wire fraud and obstruction of justice where Huawei employees were allegedly encouraged to steal technology from T-Mobile USA, Inc., a large U.S. telecommunications company.

In connection with President Donald Trump’s May 8, 2018 decision to cease U.S. participation in the Joint Comprehensive Plan of Action (JCPOA) and to re-impose all sanctions lifted or waived in connection with the JCPOA, the president has issued a new Iran-related Executive Order, “Reimposing Certain Sanctions With Respect to Iran.” This completes the first of two wind-down periods for the re-imposition of certain Iranian sanctions. The terms in the Executive Order are effective at 12:01 a.m. Eastern Daylight Time (EDT) on August 7, 2018. In addition, certain wind-down general licenses that allowed limited continued actions involving Iran will expire at 11:59 p.m. EDT on August 6, 2018.