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On February 18, 2021, the Biden Administration rescinded the United States’ re-imposition of United Nations sanctions against Iran, which were lifted as part of the Iran nuclear deal known as the Joint Comprehensive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 Sanctions Russian Government Research Institution Connected to the Triton Malware

On October 23, OFAC designated State Research Center of the Russian Federation FGUP Central Scientific Research Institute of Chemistry and Mechanics (TsNIIKhM) to OFAC’s Specially Designated Nationals and Blocked Persons List because of TsNIIKhM’s involvement with Triton malware. TsNIIKhM is a Russian government-controlled research institution. OFAC’s press release is available here. The 2017 Triton Malware … 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

US Administration Imposes Targeted Sanctions on Turkey in Relation to Syria

On October 14, 2019, US President Donald Trump signed an Executive Order (the “Order”) authorizing a range of primary and secondary sanctions on the Government of Turkey and affiliated individuals and entities. The Order followed Turkey’s launch of its “Operation Peace Spring” military operation in Syria. Following the release of the Order, the US Department … Read more