OFAC Clarifies That NGOs and Foreign Financial Institutions Do Not Risk Exposure to US Secondary Sanctions by Providing Humanitarian Assistance to Syria

On April 5, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published two new Frequently Asked Questions (“FAQs”) related to Syria. Generally, OFAC issues public guidance related to its sanctions programs in the form of FAQs published on its website. FAQ 884 clarifies that, with respect to non-US persons, OFAC … Read more

Biden Lifts ICC Sanctions, US Moves Closer to Iran Deal

The Biden Administration has announced several significant decisions over the past few days. On April 1, President Biden signed Executive Order 14022 (the “EO 14022”), terminating the national emergency declared in Executive Order 13928, dated on June 11, 2020 (“EO 13928”). EO 14022 reverses EO 13928, which blocked the property of certain persons associated with … Read more

Biden Administration Rescinds Re-Imposition of UN Sanctions, Calls for Renewed JCPOA Negotiations with Iran

On February 18, 2021, the Biden Administration rescinded the United States’ re-imposition of United Nations sanctions against Iran, which were lifted as part of the Iran nuclear deal known as the Joint Comprehensive Plan of Action (“JCPOA”). The rescission is another step in the Biden Administration’s continuing efforts to have the United States re-join the … Read more

OFAC De-designates Ansarallah, Completing Reversal of Trump Administration Yemen Policy

On February 16, 2021, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) revoked the designations of Ansarallah, the Yemeni political and para-military organization also known as the Houthis, under the Global Terrorism Sanctions Regulations (“GTSR”), the Foreign Terrorist Organization Sanctions Regulations (“FTOSR”), and Executive Order 13244. As a result, US persons no … Read more

US Federal Agencies Continue the US “Maximum Pressure” Campaign

In series of coordinated actions and announcements during the course of October and November 2020 (the Recent Iran Actions), three US federal agencies—the US Department of State (DOS), the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury, and the US Department of Justice (DOJ)—targeted both Iranian and non-Iranian entities and … Read more

OFAC Significantly Expands Sanctions on the Iranian Financial Sector

On October 8, the U.S. Treasury Department imposed sweeping secondary sanctions on the financial sector of the Iranian economy, pursuant to Executive Order (“E.O.”) 13902.  Simultaneously, OFAC designated eighteen major Iranian banks to OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”).  These new, broad sanctions apply to U.S. and non-U.S. persons, and appear … Read more