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U.S. “Maximum Pressure” Campaign Expands Isolation Of Iran’s Financial Sector

On Thursday, October 8, 2020, U.S. Secretary of the Treasury Steven Mnuchin identified the Iranian financial sector as subject to the sectoral sanctions of Executive Order (“E.O.”) 13902, escalating the formidable Trump...more

OFAC Issues New FAQs Clarifying Iran Secondary Sanctions

On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued four new frequently asked questions (“FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions...more

U.S. Government Issues Sweeping New Guidance To Maritime Industry To Address Illicit Shipping And Sanctions Evasions Practices...

In a much-anticipated and far-reaching action, on May 14, 2020, the U.S. Department of State, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the U.S. Coast Guard issued an advisory (the...more

Iran Sanctions: Snap-Back, Part 2

Executive Summary - On November 5, 2018, the United States enacted the second of two powerful phases of the “snap-back” of Iran sanctions, re-imposing sanctions that were lifted by the United States in 2016 as a result of...more

Snapback Begins: Re-Imposition of Iran Sanctions

On August 6, 2018, President Trump signed an executive order (“New Iran E.O.”) directing the Secretaries of State and the Treasury to re-impose sweeping sanctions on Iran, effecting the policy announced on May 8, 2018, to...more

MoFocus: Our Insights into the Risk + Crisis Landscape - Vol.1 Issue. 2

Arrest of a Chinese National on Hacking Charges Illustrates How U.S. Tactics Are Changing to Meet the New Cyber Threat - In August, Yu Pingan, a Chinese national, was arrested on charges that he conspired to acquire and...more

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