Tagged: iran sanctions

TD Bank and Sanctions Violations

Sanctions enforcement continues to be a significant risk. With the focus on unraveling elaborate corporate ownership schemes, the risk of conducting business with sanctioned individuals or entities is increasing. The Treasury Department’s Office of Foreign Asset Control has increased expectations regarding corporate compliance programs. In addition, OFAC encourages voluntary disclosures when violations occur, and has set out an elaborate scheme regarding transparency. On the criminal...

ZTE Pays the Price for Circumventing Sanctions and Export Controls

Here is a real zinger – clients sometimes do not tell their lawyers the truth. I will wait a minute while you get off the floor because I know everyone is shocked and amazed that this happens. But in the recent ZTE case, which we will discuss, the client company lied several times to its in-house and outside counsel resulting in false representations to the...

Sanctions Updates: Iran, Myanmar (Burma) and Cuba

With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered the sanctions landscape with the Iran Nuclear Treaty, and major changes in its relationship with Cuba and Myanmar (Burma). Since the major changes have been announced or implemented, there have been continuing...

Learning from Schlumberger’s Mistakes: Doing Business Under Iran General License H

Lauren Connell, Managing Associate at The Volkov Law Group, rejoins us for a posting on sanctions compliance.  She can be reached at lconnell@volkovlaw.com. Implementation Day has been hailed as a new stage in Iran-US relations. There has been significant media coverage of how sanctions are being lifted, with various outlets suggesting that Iran is now “open for business.” In reality, that is far from true....

The Changes to Iran Sanctions and Compliance Challenges

Putting aside the politics surrounding the Iran Nuclear Deal, the exchange of prisoners and other hot button political issues surrounding Implementation Day and the change in US-Iran relations, the new Iran sanctions create a new set of challenges for trade compliance officers. Talk about a headache — all you have to do is look at the new guidance, Frequently Asked Questions, and related documentation (Here)....

Cuba and Iran Export Compliance

I recently published an article on Trade Ready concerning export compliance and recent sanctions developments in Cuba and Iran.  A link to the article is here. Thanks for your continued support.