• On April 8, 2019, the U.S. government announced its intention to designate the Islamic Revolutionary Guards Corps (IRGC) as a Foreign Terrorist Organization, effective April 15, 2019. This unprecedented action will result...more
4/15/2019
/ Antiterrorism and Effective Death Penalty Act (AEDPA) ,
CAATSA ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Terrorist Threats ,
Trump Administration ,
U.S. Treasury
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
11/27/2018
/ Aircraft ,
Blocking Statutes ,
Cross-Border Transactions ,
Economic Sanctions ,
EU ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Humanitarian Assistance ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
SDN List ,
Special Purpose Vehicles ,
SWIFT ,
Trade Policy ,
Trump Administration ,
Vessels
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more
8/17/2018
/ Blocking Statutes ,
Economic Sanctions ,
EU ,
Executive Orders ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Winding Down ,
Withdrawal
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
On January 12, 2018, the U.S. administration took three actions relating to Iran -
• First, President Trump waived again the application of certain nuclear sanctions while making clear that the United States will refuse to...more
• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...more
11/2/2017
/ Anti-Terrorism Financing ,
Decertify ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Nuclear Agreement Review Act of 2015 (INARA) ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Legislative Amendments ,
Members of Congress ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
SDN List ,
Sunset Provisions ,
Trump Administration ,
U.S. Treasury
ANTICORRUPTION DEVELOPMENTS -
Alere Inc. Agrees to Pay More Than $13 Million to Resolve SEC FCPA Enforcement Action -
On September 28, 2017, Alere Inc. (“Alere”), a Massachusetts based manufacturer of medical diagnostic...more
10/10/2017
/ Anti-Corruption ,
Bribery ,
CFIUS ,
China ,
Consent Agreements ,
Corruption ,
Criminal Conspiracy ,
Criminal Convictions ,
Customs and Border Protection ,
De Minimus Quantity Exemption ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
ITAR ,
NCAA ,
North Korea ,
Regulatory Burden ,
Retailers ,
Securities and Exchange Commission (SEC) ,
Semiconductors ,
Suspensions & Debarments ,
Trump Administration ,
U.S. Customs ,
UK ,
Whistleblowers
ANTICORRUPTION DEVELOPMENTS -
Alere Inc. Agrees to Pay More Than $13 Million to Resolve SEC FCPA Enforcement Action -
On September 28, 2017, Alere Inc. (“Alere”), a Massachusetts based manufacturer of medical diagnostic...more
10/10/2017
/ Anti-Corruption ,
Bribery ,
CFIUS ,
China ,
Consent Agreements ,
Corruption ,
Criminal Conspiracy ,
Criminal Convictions ,
Customs and Border Protection ,
De Minimus Quantity Exemption ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
ITAR ,
NCAA ,
North Korea ,
Regulatory Burden ,
Retailers ,
Securities and Exchange Commission (SEC) ,
Semiconductors ,
Suspensions & Debarments ,
Trump Administration ,
U.S. Customs ,
UK ,
Whistleblowers
ANTICORRUPTION DEVELOPMENTS -
Alere Inc. Agrees to Pay More Than $13 Million to Resolve SEC FCPA Enforcement Action -
On September 28, 2017, Alere Inc. (“Alere”), a Massachusetts based manufacturer of medical...more
10/4/2017
/ Anti-Corruption ,
Bribery ,
CFIUS ,
China ,
Consent Agreements ,
Corruption ,
Criminal Conspiracy ,
Criminal Convictions ,
Customs and Border Protection ,
De Minimus Quantity Exemption ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
ITAR ,
NCAA ,
North Korea ,
Regulatory Burden ,
Retailers ,
Securities and Exchange Commission (SEC) ,
Semiconductors ,
Suspensions & Debarments ,
Trump Administration ,
U.S. Customs ,
UK ,
Whistleblowers
• This enforcement action highlights the heightened sanctions compliance and enforcement risk that companies face when engaging third-party consultants to perform due diligence on counterparties. U.S. persons must make clear...more
8/28/2017
/ Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
General Licenses ,
Imports ,
IPSA ,
Iran ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Settlement