JD Supra (JD Supra Iran)

On Thursday, October 8, 2020, U.S. Secretary of the Treasury Steven Mnuchin identified the Iranian financial sector as subject to the sectoral sanctions of Executive Order (“E.O.”) 13902, escalating the formidable Trump Administration sanctions campaign against Iran. In accordance with this announcement, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) strengthened its...

Summary - After the United Nations Security Council (“UNSC”) declined to extend a conventional arms embargo on Iran, the United States sought to unilaterally trigger a UN sanctions “snapback” provision and issued a new Executive Order to restrict arms trade with Iran by non-U.S. persons. Neither the snapback of UN sanctions, if effective, nor the new EO should substantially change financial...

The Council of the European Union has extended its human rights sanctions against Iran until 13 April 2021. ???????

On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under the Global Terrorism Sanctions Regulations (GTSR) or the Iranian Transactions and Sanctions Regulations (ITSR). Please see full Publication below for more information.

On 10 January 2020, in response to missile attacks by the Iranian military targeting two U.S. bases in Iraq, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a number of senior Iranian military leaders, Iranian metals companies, as well as third-country entities and a vessel on the List of Specially Designated Nationals and Blocked Persons (SDN List)

The Department of Homeland Security (DHS) is warning critical infrastructure operators to be on high alert for Iranian backed cyber-attacks because of the vulnerability of state and municipal computer systems, they are at high risk for attack from Iranian-based hackers.

Following the escalation of tensions between the United States and Iran in the past week, the Health Information Sharing and Analysis Center (H-ISAC) is warning hospitals and health systems that Iran could attack health organizations, which are considered critical infrastructure, and that they make sure their systems are being updated with patches.

The Department of Homeland Security (DHS) issued a grave warning to U.S. businesses and critical infrastructure operators on January 6, 2020 alerting the public that Iran poses a cyber terrorism threat to the United States following the death of Iranian Quds Force commander Gen. Qassem Soleimani.

In view of Iran’s vows to retaliate against the United States for the death of Quassem Soleimani, the NYDFS has issued an industry letter  to all regulated entities regarding the need for heightened cybersecurity precautions.

Iran is the second largest economy in the Middle East, despite years of international sanctions, and the market of more than 80 million people is highly consumer oriented. Demand for local and foreign products is consequently very high and the temptation to produce similar or counterfeit products (from foreign or local competitors) is very strong.

As described in our prior alert, November 5, 2018 marked the full return ("snapback") of U.S. Iran-related sanctions measures lifted or waived pursuant to the Iran nuclear deal (the Joint Comprehensive Plan of Action or "JCPOA").

On 5 November 2018 the United States re-imposed the remaining nuclear-related secondary sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) against Iran that previously had been lifted pursuant to the United States' commitment to the Joint Comprehensive Plan of Action (JCPOA). Please see full Publication below for more information.

Withdrawal from the Iran nuclear agreement triggers full implementation of US sanctions, including threat of “secondary” sanctions on non-US persons dealing with Iran. As reported in the Latham Client Alert dated May 10, 2018, President Trump announced on May 8 that the United States was withdrawing from the Joint Comprehensive Plan of Action (JCPOA), the January 2016 nuclear non-proliferation

On November 5, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) will reimpose certain economic sanctions against Iran that had been held in abeyance under the Joint Comprehensive Plan of Action (“JCPOA”), an international agreement intended to restrain Iran’s nuclear program. This action requires U.S. companies to ensure their global compliance policies prevent non-U.

The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the Iran nuclear deal. Please see full Publication below for more information.

In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR) and revoked General Licenses (GL) H and GL I. In the Frequently Asked...

Crucial Points - Previously Lifted or Waived Sanctions Measures Coming Back Into Effect: On May 8, 2018, the U.S. President terminated U.S. participation in the Iran nuclear agreement. As a result, U.S. Iran-related sanctions measures lifted or waived pursuant to the agreement are generally to come back into effect – or "snapback."

It has now been two years since Iran-related sanctions relief took effect under the Joint Comprehensive Plan of Action. While U.S. persons continue to be generally prohibited from engaging in Iran-related business, the JCPOA clearly expanded opportunities, from a sanctions perspective, for non-U.S. persons (including foreign subsidiaries of U.S. companies under General License H) to do business...

Press reports indicate that President Trump intends to “de-certify” the Iran nuclear deal this week. In practical terms, that means he would refuse to re-certify one or more statutory elements of a law passed by the U.S. Congress pertaining to Iran’s obligations under the deal and the merits of providing sanctions relief to Iran. The next deadline for certification is October 15, 2017. Please...

Hackers working on behalf of the Iranian government have been targeting the aviation and petrochemical industries in the United States, Saudi Arabia, and South Korean since 2013, according to a report released by FireEye recently.

On July 17, 2017, the U.S. State Department certified that Iran continues to meet the conditions of the Iran nuclear agreement known as the Joint Comprehensive Plan of Action, or JCPOA. As a result, for the next 90 days, the United States will maintain significant reductions in its sanctions against Iran as provided in the JCPOA.

The Iranian pharmaceutical and healthcare products market has had steady growth during the last decade. There have been significant improvements in living standards in Iran, in particular adequate access to healthcare facilities in urban areas and developing access in rural regions due to government policies. These obviously have entailed a remarkable growth in the demand for consumer health...

On Friday, February 3, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced it was designating 25 entities and individuals as Specially Designated Nationals (SDNs) for their involvement in procuring technology and/or materials to support Iran's ballistic missile program, as well as for acting for or on behalf of, or providing support to, Iran's Islamic...

The Trump Administration responded on Feb. 3, 2017, to Iran's latest series of ballistic missile tests by sanctioning certain individuals and companies involved in Iran's efforts to procure ballistic missile technology or otherwise support the Iranian Islamic Revolutionary Guard Corps (IRGC).

Iran is said to be targeting an increase in oil production from 3.85 to 4 million barrels per day by the end of 2016. Iran is also hoping to start export of a new heavy oil, called West Karun, and which is expected to compete with Iraq’s Basra Heavy crude, which has gained a significant market with US and Asian refiners since its launch in 2015.

The sanctions stranglehold on Iran is loosening as the Obama Administration continues to chip away at restrictions on the commercial passenger aircraft industry. Pursuant to the phased enactment of the Joint Comprehensive Plan of Action (JCPOA), last month the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License I (GL I), which authorizes U.S. persons to...

- Sanctions relief presents new business opportunities with Iran - Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies - The line between permitted and prohibited financial transactions by non-U.S. banks is not clear - Careful advice of counsel is critical

As we look forward to the release of the new model Iranian Petroleum Contract, Dentons' oil and gas partners James Dallas and Alistair Black analyse the contents of the recently released "Principles of the New Contract Model" (the Principles) and the possible implications for international oil companies (IOCs) looking to invest in this very promising jurisdiction.

On March 24, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License I authorizing U.S. persons to undertake certain transactions ordinarily incident to the negotiation of, and entry into, contingent contracts for licensable activities under OFAC’s Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial...

January 16, 2016, marked the Implementation Day that recognised the certification by the International Atomic Energy Agency that Iran had met its obligations under the July 2015 Joint Comprehensive Plan of Action (JCPOA), a deal between Iran, the European Union, France, Germany, the United Kingdom, China, the Russian Federation and the United States, to lift nuclear-related sanctions in exchange...