On November 5, 2018 the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) completed the process to re-impose the Iran sanctions program. The 180-day wind-down period for termination of the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) ended. As part of the re-imposition of U.S. sanctions, OFAC added more than 700 individuals, entities, aircraft, and vessels to the SDN List,...
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