Sanctions

On May 8, 2018, President Donald Trump announced that the U.S. will withdraw from the Iran nuclear deal, formally known as the Joint Comprehensive Plan of Action (JCPOA), and reimpose the strict economic sanctions program that was in place prior to the landmark 2015 agreement.  Based on the guidance issued by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), the reimposed sanctions will impact businesses outside of the U.S. that engage in  business with or in Iran, particularly those who do so while also seeking to maintain or establish a U.S. presence or dealings with U.S. companies. The “secondary sanctions” control who those foreign entities can do business with and restrict how foreign entities can utilize the U.S. financial system.  Foreign persons and businesses can also be held liable for causing U.S. persons to violate sanctions regulations. (more…)

On May 8, President Trump announced that the U.S. will withdraw from the Iran nuclear deal, formally known as the Joint Comprehensive Plan of Action (JCPOA), and reimpose the strict economic sanctions program that was in place prior to the landmark 2015 agreement. The U.S. Treasury Department’s Office of Foreign Assets Control issued a Frequently Asked Questions document in coordination with the announcement to assist with the implementation of the Iran sanctions program. Here is the bottom line so far.

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On December 21, the U.S. Treasury Department announced the implementation of a new global sanctions regime under the Magnitsky Human Rights Accountability Act (the “Global Magnitsky Act”).  President Trump issued an Executive Order declaring a national emergency with respect to human rights abuses and global corruption, targeting individuals and entities spanning nations across the world, including Russia, Ukraine, Uzbekistan, Pakistan, Nicaragua, and elsewhere. (more…)

On December 12, a key deadline passed for Congress to reimpose nuclear-related sanctions against Tehran, shifting the pressure back to the executive branch and setting new deadlines that will be critical to the fate of the 2015 Iran nuclear deal.  In October, President Trump refused to certify Iran’s compliance with the 2015 Joint Comprehensive Plan of Action (JCPOA), calling on Congress to set “trigger points” related to Iran’s nuclear and ballistic missile programs, and setting off a 60-day window for lawmakers to reimpose secondary sanctions that have been suspended under the terms of the JCPOA.  That window closed on December 12 without any Congressional action. (more…)

As we discussed further at length here, the U.S. and nations around the world have recently sought to implement and impose harsh economic sanctions programs against  North Korea to pressure Pyongyang into ceasing its development of a nuclear weapons program.  The international community has ramped up its pressure by adopting increasingly severe measures since August, when President Trump signed into law a wide-ranging sanctions bill titled the Countering America’s Adversaries Through Sanctions Act (CAATSA), and the UN Security Council followed suit by unanimously passing a US-drafted resolution targeting $1 billion worth of the DPRK’s primary exports. (more…)