Farhad Alavi Quoted by New York Times

I was quoted in the New York Times on an article regarding the impact of sanctions on the rescission of an employment offer by the US Tennis Association (USTA) to an Iran-based tennis referee. The article discusses the on the need in this case for the referee, Adel Borghei, to obtain approval from the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) to be able to work in such a capacity.

The article really speaks to what I call the “personal” impact of the sanctions.  Many of these laws may have valid rationale, but they do wind up impacting individuals and organizations in ways that OFAC and other government officials likely never really thought.  The provision in the law that prohibits the USTA from hiring Mr. Borghei for this case was likely put into effect to prohibit Iranians from being recruited here for small tasks that could harm security, etc., not for athletic activities like this.  OFAC regulations impact a whole host of even more benign personal activities. Given that the Administration has evidently hinted that it wants to lower the restrictions on basic activities in order to rachet up enforcement on more high level matters (as seen by recent reforms in the Iranian Transactions and Sanctions Regulations, ITSR, and the new General License D authorizing certain computer-related exports to Iran) it would be interesting if this case causes OFAC to issue guidance or perhaps even repeal certain limitations that are cumbersome both for individuals and for the enforcers.


An international trade compliance (sanctions, export controls, customs, anti-corruption) and defense lawyer.

Posted in Iran, OFAC, Personal, Sanctions, Uncategorized

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Akrivis Law Group, PLLC
Washington, DC

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This website aims to provide notes and commentary on international legal, business, and political developments in economic and other sanctions. It is intended solely for information and entertainment purposes and should in no way be construed as legal advice. Laws, regulations, and policies change from time to time so some information on older posts can very easily be dated. If you have any questions or are unclear on any of the subject matters addressed or discussed on this site, please consult a licensed legal professional. Views presented in the comments and outside links do not necessarily reflect those of the website author. All external links on this website to articles and documents are external and provided for informational purposes only. They have no relation to the author of this website unless specified otherwise.

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Copyright 2023 Farhad R. Alavi.

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