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President Trump Announces U.S. Withdrawal from JCPOA; U.S. Sanctions on Iran will be Re-imposed Following Wind-Down Periods

• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a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

OFAC Pushes New Limits on Jurisdiction of U.S. Sanctions by Penalizing Non-U.S. Companies for “Causing” Violations by Making U.S....

On July 27, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the civil settlement with CSE TransTel Pte. Ltd. (“TransTel”) and CSE Global Limited (“CSE Global”) in the amount of...more

Trump Administration Makes First Iran Sanctions Designations

Key Points - - The U.S. Department of the Treasury’s Office of Foreign Assets Control has added 25 new entities and individuals to its Specially Designated Nationals List, including some located in China, Lebanon,...more

OFAC Guidance on U.S. Dollar Transactions Involving Iran

On October 7, 2016, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) published new guidance clarifying (a) circumstances under which non-U.S. financial institutions (FFIs) may engage in U.S. dollar...more

What Implementation of the Iran Nuclear Deal Means for Non-U.S. Companies

On January 16, 2016, the International Atomic Energy Agency (IAEA) verified, and U.S. Secretary of State John Kerry confirmed, that Iran had implemented its key nuclear-related measures described in the Joint Comprehensive...more

What Implementation of the Iran Nuclear Deal Means for U.S. Companies and Their Subsidiaries Abroad

If you read one thing... - There are far greater opportunities for U.S. companies with respect to Iran, particularly through foreign subsidiaries and in the commercial aviation sector, however, U.S. persons and...more

Sanctions Relief to Expect from the Nuclear Deal with Iran

On July 14, 2015, Iran and the P5+1 countries (China, France, Germany, Russia, the United Kingdom and the United States), with the High Representative of the European Union for Foreign Affairs and Security Policy, finalized...more

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