Designated: A Sanctions Podcast EP3: Cross over event with The Bettor’s Verdict

In a special podcast cross over event, the Designated team joins The Bettor’s Verdict to discuss the Impact of Crypto on Sanctions and AML Laws in the United States.  In this episode, Designated host Jonathan Cross, is joined by The Bettor’s Verdict host Steve Jacobs, and Herbert Smith Freehills Partner John O’Donnell. Jonathan, Steven and … Read more

OFAC Enters Settlement Agreement With a U.S. Company Related to Certain Exports to Iran Through Non-U.S. Distributors

On September 9, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with NewTek, Inc. (“NewTek”), headquartered in San Antonio, Texas. According to a press release, NewTek agreed to pay $189,483 to settle its potential civil liability for 52 apparent violations of the Iranian Transactions and Sanctions … Read more

Companies May Risk Violating U.S. Sanctions Against the Taliban by Conducting Business With the Government of Afghanistan

Now that the Taliban controls Afghanistan, many businesses with economic interests or investments in the country are reevaluating potential sanctions risks. Indeed, a former OFAC official explained that, “[t]his is a new world,” and that he could not “think of any case in which a terrorist group that’s already designated became the power in charge … Read more

Designated: A Sanctions Podcast EP2: History of US Sanctions Under the JCPOA May Offer Insight to Terms of Renewed JCPOA Participation

In this episode, Jonathan Cross, Brittany Crosby-Banyai and Dan Hudson discuss the history of the Iran sanctions program under the Iranian nuclear deal, known as the Joint Comprehensive Plan of Action (“JCPOA”). They also analyze the mechanisms by which sanctions were re-imposed when the US left the agreement. These considerations offer insight as to the … Read more

OFAC Enters Settlement Agreement With a Non-U.S. Company, and its U.S. Parent Company, Related to Violations of Iran and Syria Sanctions

On August 27, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with First Bank SA (“First Bank”), located in Romania, and its U.S. parent company, JC Flowers & Co. (“JC Flowers”). According to a press release, the companies agreed to pay $862,318 to settle potential civil … Read more

OFAC Reaches Settlement with Alfa Laval Subsidiaries Over Iran Referral

On July 19, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had entered into settlement agreements with two subsidiaries of Alfa Laval AB, the UAE-based Alfa Laval Middle East Ltd. (“AL Middle East”) and the US-based Alfa Laval Inc. (“AL US”) to settle apparent violations of the Iranian Transactions and … Read more

Biden Administration Adds 34 Entities to BIS Entity List

On July 12, 2021, the Commerce Department’s Bureau of Industry and Security (BIS) published a Federal Register notice amending the Export Administration Regulations (EAR) by adding 34 entities to the BIS Entity List under 43 entries. The Entity List prohibits US companies from exporting or transferring US products and technology to listed entities without a … Read more

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