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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 […]

First Wave of U.S. Sanction on Iran Snap Back; Countries Seek Waivers to U.S. Sanctions

On August 7, 2018, the U.S. reinstated the first wave of sanctions against Iran as the 90-day wind-down period concluded. The Trump administration reimposed sanctions that prohibit Iran purchasing U.S. banknotes, commercial aircraft, trading gold and metals, and business with Iran’s automotive sector. The snapback provisions were evoked by President Trump’s May 8, 2018 decision […]

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 […]

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 […]

A Closer Look at OFAC’s General License H

OFAc's General License H: A Closer Look

Back in July (2015) the permanent members of the UN Security Council (China, France, Russia, the United Kingdom, and the United States), Germany (collectively the P5+1), the European Union, and Iran reached a Joint Comprehensive Plan of Action (JCPOA) to ensure that Iran’s nuclear program would be exclusively peaceful.

Vienna Agreement With Iran: New Opportunities For U.S. Companies?

Agreement With Iran & New Opportunities For U.S. Companies

The Agreement concluded by the six world powers and the Islamic Republic of Iran in regard to its nuclear program, represents an historic moment in the diplomatic relations between the United States and Iran and, simultaneously, opens to the American business-world the possibility of new and previously unimaginable opportunities. Though the Joint Comprehensive Plan of […]

U.S. Secondary Sanctions System Part 3

Secondary Sanctions System in the U.S.

Impact on European Banks and Companies Click Here For Part 2 As stated in Part 1 of this series, the secondary sanctions system also impacts European companies, and this is through Executive Order 13608 signed by President Obama on May 1, 2012.  This Order gave to the Department of the Treasury the authority to impose […]

U.S. Secondary Sanctions System Part 2

Addresses Terrorist Finance Elimination and Legitimate Transaction and Family Remittance Enhancement

Impact on European Banks and Companies Click Here For Part 1 Click Here For Part 3 Executive Order 13622, signed by President Obama, allows the possibility of imposing sanctions against any foreign financial institutions conducting or facilitating any significant financial transaction with the Iranian state oil companies, for the purchase of petroleum or petrochemical products.[1] […]

The U.S. Secondary Sanctions System

Secondary Sanctions Program in the U.S.

Impact on European Banks and Companies The American sanctions system against the Islamic Republic of Iran found its origins some years after the outbreak of the Iranian Revolution of 1979, becoming more restrictive in 1995 when President Clinton (see right) prohibited U.S. persons and entities from engaging in most transactions with Iran.[1] These restrictions concerned […]

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