Tagged: secondary sanctions

The Long Arm of OFAC: Secondary Sanctions, Facilitation, and Causing a Violation

Matt Stankiewicz, Senior Associate at The Volkov Law Group, rejoins us for a blog posting on OFAC sanctions law. Matt can be contacted at mstankiewicz@volkovlaw.com. Sanctions law can be complex.  The sanctions programs themselves are often a tangled web of do’s and don’t’s – various wind down periods, General Licenses, payment structures, and more.  In order to enforce these laws and regulations, OFAC must necessarily...

Episode 55 — Update on the Iran Sanctions Program

On May 8th, 2018, the Trump administration withdrew from the Joint Comprehensive Plan of Action or JCPOA and began to reimpose the U.S. nuclear-related sanctions.  All of the sanctions in existence prior to the JCPOA including nuclear-related secondary sanctions will be effective on November 5, 2018.  The wind-down of Iran-related activities pursuant to authorizations provided by the JCPOA is required in two wind-down periods – a 90 day...

OFAC Begins to Re-Impose Iran Sanctions and Expands Reach of Previous Sanctions

The Trump Administration issued a new executive order on August 6, 2018, in order to reimpose the first tranche of the Iran sanctions lifted by the former Joint Comprehensive Plan of Action (“JCPOA”).  In doing so, the executive order consolidates relevant sanctions authorities and broadens the scope of the previous restrictions. Companies will now have to comply with a renewed set of secondary sanctions, and...