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What’s Going to Happen with Exports of Commercial Drones?

In 2015, many believed to have seen an announcement by the Department of State relaxing drone exports, but a close look at the announcement suggests otherwise. According to a publication by the Directorate of Defense Trade Controls, “The FAA Modernization and Reform Act of 2012 for Unmanned Aircraft Systems (http://www.hse-uav.com/faa_modernization_and_reform_act_2012.htm) creates a statutory basis for […]

Trends in OFAC Enforcement

By Juhi Tariq – Which cases have been considered egregious? AIG Case – June 26, 2017 Though the transactions totaled almost double the amount, OFAC’s base penalty for AIG was $198, 226. Mitigating factors: No prior penalty notice or Finding of Violation from OFAC in the past five years Existence of a compliance program that […]

Russia Sanctions Bill Signed

From NYT: President Trump signed legislation on Wednesday imposing sanctions on Russia and limiting his own authority to lift them, but asserted that the measure included “a number of clearly unconstitutional provisions” and left open the possibility that he might choose not to enforce them as lawmakers intended. In particular, he objected to Congress interfering with the […]

China, India, and Turkey still buying large amounts of Iranian oil

China, India, and Turkey are showing signs of not slowing down their oil imports from Iran even though the Trump administration has threatened sanctions on those who continue to import Iranian oil. Global oil prices have risen since the announcement of the reimposition of U.S. sanctions on Iranian oil but major international players continue to seek access […]

Did Salt Bae Commit a Crime by Serving Venezuelan President Maduro?

Photo: Twitter/@Nusr-ett Amidst the public outrage and protests against Salt Bae and Nusr-Et Steakhouse, the meat slicing and salt pouring icon may have inadvertently stumbled into the world of U.S. economic sanctions, which currently target the President of Venezuela, Nicolas Maduro. While the U.S. government may investigate and enforce any applicable sanctions violations, these lamb chops also provide […]

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 […]

JCPOA-related Waived U.S. Sanctions Snap Back on Iran

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 […]

U.S. Withdrawal from the JCPOA

President Trump announced the withdrawal of the United States from the Joint Comprehensive Plan of Action (“JCPOA”), commonly known as the “Iran Deal”, on May 8, 2018. The United States, Germany, UK, China, and Russia collectively signed the JCPOA in an effort to regulate Iran’s nuclear program in exchange for the removal of multilateral economic and […]

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