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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 […]

Indicted, Extradited, and Sanctioned

Alleged Foreign Drug Traffickers Defense Challenges

Legal & Practical Challenges to Representing Alleged Foreign Narcotics Traffickers Foreign nationals face several unique challenges when forced to appear in the United States to face allegations that they are narcotics traffickers.  Many foreign nationals facing extradition to the United States for narcotics trafficking have been indicted by at least one grand jury.  The grand […]

Syria Sanctions: OFAC Issues New General License Authorizing Publishing-Related Transactions

Publishing Transactions in Syria Authorized by OFAC

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) commonly issues general licenses to sharpen and fine tune its country-based sanctions programs to minimize unintended consequences.  On April 13, 2015, OFAC issued a new general license in the Syrian Sanctions Regulations, promulgated pursuant to Executive Order 13338.  This new general license authorizes […]

Executive Order Authorizes OFAC Targeting of Venezuelan Officials

Venezuelan Officials Targeted by OFAC through Executive Order

Executive Order 13692: Expands Upon Congressional Legislation; Authorizes OFAC To Designate Venezuelan Officials for Their “Status,” Not Their “Conduct.” Like many sanctions programs before it, the Venezuela-related OFAC sanctions program is implemented pursuant to the International Emergency Economic Powers Act (IEEPA).  However, one unique aspect of this sanctions program is that it is also implemented […]

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