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Iran

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On October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) identified the Iranian financial sector as subject to Executive Order (EO) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below. The action represents a significant escalation of the sanctions targeting Iran’s financial sector, yet many humanitarian transactions and activities will…

On October 1, 2020, the Office of Foreign Assets Control (OFAC), Treasury, published in the Federal Register a final rule amending the Weapons of Mass Destruction Proliferators Sanctions Regulations (WMD Regulations; 31 CFR part 544) to update a note to describe how persons designated pursuant to the WMD Regulations for North Korea-related activities are identified on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List). Specifically, OFAC is amending the note to explain that…

On September 15, 2020, US Customs and Border Protection (CBP) and the Transportation Security Administration (TSA) published in the Federal Register a document that announces the decision of the Secretary of the Department of Homeland Security (DHS) to terminate arrival restrictions applicable to certain flights. Specifically, the document terminates arrival restrictions that are applicable to flights carrying persons who had recently traveled from, or were otherwise present within, the People’s Republic of China (excluding the…

On June 5, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published four Frequently Asked Questions (FAQs) regarding Iran-related sanctions under Executive Order 13902 (EO 13902). EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in “significant transactions” or providing “material support” to parties designated pursuant to the order. Our blog post regarding EO 13902 is available here. The FAQs reconfirm that Iranian manufacturers of medicines,…

On May 14, 2020, the US Department of State, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the US Coast Guard issued guidance to the private sector aimed at preventing deceptive shipping practices used in sanctions evasion, smuggling, facilitation of terrorism, and other criminal activity (the “Advisory”). The Advisory focuses on tactics recently used by malign actors to evade sanctions and sets out a non-exhaustive list of best practices companies may wish…

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has issued an FAQ providing guidance relating to the provision of humanitarian goods and assistance to Iran in response to the Coronavirus Disease 2019 outbreak there. The guidance summarizes existing legal authorities that may authorize such humanitarian activities, which include: The making of humanitarian donations from the US or by US persons to recipients in Iran (other than to the Government of Iran, persons on OFAC’s SDN…

On March 17, 2020, US Customs and Border Protection (CBP) and the Transportation Security Administration (TSA) published in the Federal Register a document notifying the public of certain arrival restrictions. The document announces the decision of the Secretary of Homeland Security (DHS) to direct all flights to the United States carrying persons who have recently traveled from, or were otherwise present within, the countries of the Schengen Area to arrive at one of the United…

On January 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued a new Counter Terrorism and Iran-related General License No. 8 (“GL 8”) together with new frequently asked questions (“FAQs”) about the general license and the Swiss Humanitarian Trade Arrangement (“SHTA”). New GL 8 authorizes US Persons and non-US entities owned or controlled by US Persons to engage in Iran-related humanitarian transactions even if the CBI is directly or indirectly involved. Although the US Government…

On March 4, 2020, US Customs and Border Protection (CBP) and the Transportation Security Administration (TSA) published in the Federal Register a document notifying the public of certain arrival restrictions. The document adds to the existing restrictions by directing all flights to the United States carrying persons who have recently traveled from, or were otherwise present within, the Islamic Republic of Iran to arrive at one of the United States airports where the USG is…

On February 14, 2020, the Department of State published in the Federal Register a notice [Public Notice: 11034] that measures imposed pursuant to Section 3 of the Iran, North Korea, and Syria Nonproliferation Act (the Act) described in this notice against 13 persons went into effect February 3, 2020. A determination has been made that a number of foreign persons have engaged in activities that warrant the imposition of measures pursuant to Section 3 of…