Sanctions

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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…

The Department of Commerce’s Bureau of Industry and Security (BIS) further tightened U.S. sanctions on Cuba “for its repression of the Cuban people and its support of the Maduro regime in Venezuela.” Overall, the United States maintains a comprehensive embargo on trade with Cuba, and the export and reexport to Cuba of items subject to…

On October 14, 2019, President Donald Trump announced U.S. economic sanctions directed at the government of Turkey in response to Turkey’s military action in northeast Syria, “including but not limited to indiscriminate targeting of civilians, targeting of civilian infrastructure, targeting of ethnic or religious minorities, or targeting or other actions that undermine the continued counterterrorism…

In September, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) continued to tighten its sanctions on Iran and Venezuela, and addressed a sanctions-evading scheme for Syria involving several Russian entities.

  • Iran: On September 20, 2019, OFAC announced that it was designating the Central Bank of Iran (CBI), the National Development

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The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that, effective October 9, 2019, the Cuban Assets Control Regulations (CACR) will be amended to further restrict certain financial transactions involving Cuba and to deny Cuba access to hard currency. In a press release, OFAC announced that these changes will amend certain…