President Trump’s decision to reimpose U.S. sanctions, after pulling-out of the Iran Nuclear Deal (JCPOA) has deepened the divide with the EU. On 07 August 2018, the EU announced that its blocking statute entered into force. Anyone already in the Iranian market or thinking of entering it, must take note that the global trade compliance risks have increased significantly. Time will tell whether both moves are wise.
U.S. Iran sanctions
On 06 September 2017, the U.S. Department of Justice announced that it’s broadening the ongoing investigation into Turkish violations of U.S. Iran sanctions. The investigation includes a probe into the conduct of a former Turkish Minister of the Economy who allegedly received bribes and kick-backs to conceal U.S. Iran related sanctions violations.
On 27 July 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control published a settlement agreement with Singapore based CSE Global Limited and CSE TransTel Pte. Ltd. Both companies agreed to pay $12,027,066 to settle potential civil liability for 104 violations of the Iranian Transactions and Sanctions Regulations (“ITSR”) and the International Emergency Economic Powers Act (“IEEPA”). The case is an example of the expanding extra-territorial reach of U.S. sanctions.
On 15 June 2017, the U.S. Senate overwhelmingly voted to adopt new sanctions against Iran. The new sanctions are framed in the Countering Iran’s Destabilizing Activities Act of 2017 (S.722). Text of S.722 can be found here. …
On 18 April 2017, U.S. Secretary of State Rex Tillerson certified to Congress that Iran is in compliance with the recently concluded Nuclear Deal – Joint Comprehensive Plan of Action (JCPOA). However, he also announced that President Trump would start an inter-agency to review on the appropriateness of U.S. Iran sanctions relief.
On 28 February 2017, OFAC announced a $515,400 settlement agreement with United Medical Instruments, Inc. regarding 56 violations of U.S. Iran sanctions. The violations occurred between 2007-2009.
In the brief weeks that President Trump has been in office, he has commenced to implement his campaign pledges. Despite his ranting to put Iran on notice, regarding its most recent ballistic missile test, it’s…
On 22 December 2016, U.S. Treasury/ OFAC published its updates regarding the Iranian Transactions and Sanctions Regulations (31 C.F.R. 560 ITSR). OFAC has decided to expand the scope of medical devices and agricultural commodities authorized for (re)export to Iran pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), as amended. This amendment also includes, amongst others, new or expanded authorizations related to the definition of Iranian-origin goods, training, replacement parts, software and services for the operation, maintenance, and repair/recall of medical devices.
On 15 December 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control updated its FAQ’s regarding the uplifting of sanctions under the JCPOA. The revision of the FAQ’s aim to clarify the U.S. intentions in regard to the triggering of JCPOA snap-back provisions. At the same time OFAC also introduced General License (GL) J-1 to allow the re-export of civilian aircraft to Iran (Authorizing the Re-exportation of Certain Civil Aircraft to Iran on Temporary Sojourn and Related Transactions).
The New York Department of Financial Services (DFS) has published its decision to fine Italian financial giant Intesa Sanpaolo $ 235 Million for repeated anti-money laundering and sanctions violations. The misconduct included processing numerous suspicious transactions involving shell companies through the New York branch and deliberately concealing information from Bank Regulators.