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Closure of 90-day Wind-Down Period Instills Fear; Auto Industry Halts Investments

Secondary Sanctions Program in the U.S.

With the first wave of reinstated sanctions hitting Iran on August 7, 2018, German carmaker Daimler froze its plans to expand into the Iranian market. Daimler, the world’s biggest luxury carmaker and commercial vehicles manufacturer, has reversed its 2016 plans to re-establish ties with Iran’s automotive industry. In 2016 Daimler established a joint venture with […]

Decertifying the Iran Deal

President Trump must make a decision prior to October 15th on the certification of the Iran Nuclear Deal or Joint Comprehensive Plan of Action (JCPOA) that was implemented in January 2016. If it were decertified, the onus would be on the U.S. Congress to decide in 60 days whether to impose nuclear-related sanctions that were […]

President Obama Sanctions Russian Entities and Individuals for Tampering with Election

Russian Entities Sanctions for election tampering

On December 29, 2016, President Obama took action to expand the scope of the Department of the Treasury’s Cyber-related Sanctions Program to include, among other things, tampering with election processes.  Specifically, the President issued an Executive Order, Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities. This Executive Order […]

Eliminating Terrorist Financing Without Damaging Legitimate Transactions

Addresses Terrorist Finance Elimination and Legitimate Transaction and Family Remittance Enhancement

Eliminating Terrorist Funding while Enhancing Legitimate Commercial Transactions and Family Remittances There is consensus that financing terrorism, via the international financial system, must be systematically eradicated while maintaining channels for legitimate commercial and family-related financial transactions.  Unfortunately, many international banking conglomerates refuse to do business with certain countries altogether, as their costs of compliance outweigh […]

New OFAC Secondary Sanctions Against Hizballah

Sanctions for Foreign Banks Business with Hezbollah

OFAC Issues Secondary Sanctions for Foreign Banks Doing Business with Hizballah On April 14, 2016, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new secondary sanctions (found in 31 C.F.R. 566 (pdf)) to implement the Hizballah International Financing Prevention Act of 2015. The new secondary sanctions target foreign financial institutions […]

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