Congress ChamberYesterday, July 25th, the U.S. House of Representatives passed the “Countering America’s Adversaries Through Sanctions Act” by a vote of 419-3. The bill originated as an act in the Senate which was focused on Iran. In response to Russian meddling in the U.S. election, the Senate expanded that bill to include additional sanctions against Russia, codify various Russia-Ukraine sanctions promulgated by the Obama Administration into law and add procedural provisions to delay or prevent any efforts by the Trump Administration to relax those codified Obama Administration sanctions. The Senate passed their revised version of this legislation last month by a vote of 98-2. For more information on the Senate’s earlier approval, please see our post on June 16th.

Continue Reading Congress Passes Russian Sanctions Bill with New Sanctions on Russia, Iran and North Korea

immigrationIn agreeing to review two rulings by the 4th Circuit Court of Appeals and 9th Circuit Court of Appeals on President Trump’s March 6, 2017, Executive Order, the Supreme Court reinstated certain provisions of the Executive Order that the lower courts had blocked. The March 6th Executive Order entitled “Protecting the Nation from Foreign Terrorist Entry into the United States” was to suspend visa issuance for individuals from six countries, including Libya, Iran, Somalia, Sudan, Syria, and Yemen for 90 days. This provision, often referred to as the “travel ban,” effectively prohibits travel to the United States for individuals from the six affected countries.

Continue Reading Supreme Court Allows Major Provisions of Travel Ban to Go Into Effect

globeIn March 2016, ZTE Corporation and ZTE Kangxun (collectively ZTE) were placed on the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) Entity List after corporate documents revealed alleged failure to comply with U.S. sanctions against Iran. While placement on the Entity List would ordinarily result in a ban on conducting business with the U.S., President Obama issued a Temporary General License (TGL) on March 24, 2016, which authorizes the export, reexport and transfer (in country) of items to ZTE. The TGL was implemented by amending the Export Administration Regulations (EAR) with the addition of Supplement No. 7 to part 744.

Continue Reading ZTE’s TGL Extended until March 29

The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has taken two unrelated sanctions actions against Iran over the past several days:

SDN Designations in Response to Ballistic Missiles Tests

world health globeEffective February 3, 2017, OFAC imposed sanctions against 13 individuals and 12 entities with ties to Iran’s ballistic missile program. OFAC added these individuals and entities to its list of Specially Designated Nationals (the “SDN list”) freezing all  of their assets held in the U.S. and prohibiting persons subject to U.S. jurisdiction from engaging in trade with the sanctioned individuals and entities. These sanctions also apply to non-U.S. persons on a secondary basis. In a press release, OFAC Acting Director John E. Smith stated “Iran’s continued support for terrorism and development of its ballistic missile program poses a threat to the region, to our partners worldwide, and to the United States” and also added “We will continue to actively apply all available tools, including financial sanctions, to address this behavior.”


Continue Reading OFAC Sanctions Iran Missile Program Supporters and Imposes New Medical Device Licensing Requirements

cargo ship containersThe Department of Treasury’s Office of Foreign Assets Control (OFAC) has announced new rules, which will take effect December 23, 2016, amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). The revised rules expand the scope of medical devices and agricultural commodities that may be exported or re-exported to Iran without specific authorization, pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA).
Continue Reading OFAC Amends Iran Sanctions to Ease Humanitarian Trade

Treasury BuildingOn December 15, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) revised their Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA), clarifying procedures related to the potential “snapback” of the JCPOA and the subsequent re-imposition of sanctions.
Continue Reading OFAC Clarifies Procedures for Potential Snapback of Iran Sanctions

On July 14, 2015, following nearly twenty months of talks, international negotiators from seven countries (the United States, the United Kingdom, China, France, Germany, Russia, and Iran) announced that they reached a landmark nuclear agreement to limit Iran’s nuclear program. While this is a historic agreement long in the making, it is important to note that there is no immediate lifting of sanctions against Iran. U.S. government officials have indicated that for now it is status quo for those focused on sanctions compliance.

Continue Reading Iran and World Powers Announce Landmark Nuclear Agreement

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On June 30, the United States, together with its partners in the P5+1, the EU and Iran, agreed to a seven day extension of the Joint Plan of Action (JPOA), which currently halts progress on Iran’s nuclear program in order to continue negotiations towards establishing a comprehensive and enduring solution.  The initial agreement, reached in November 2013, stipulated that the P5+1 (comprised of the United States, the United Kingdom, France, China, Russia, and Germany) would implement narrow and targeted sanctions relief in return for Iran’s continued commitment to limit its nuclear program.


Continue Reading Iran Negotiations Joint Plan of Action Extends Sanctions Relief through July 7, 2015

Flag of CubaWhile Iran has taken center stage in current foreign policy discussions, Congress and the Administration are keenly aware that Cuba is on deck. Following President Obama’s historic meeting with Cuban President Raúl Castro and his announcement of intent to remove Cuba from the list of states that sponsor terrorism, members of Congress have responded by introducing bills both supporting and opposing the President’s policies, including:

Continue Reading Lawmakers Continue Taking Sides on Cuba while Cities Begin Taking Action