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.