OFAC slapped a $2 million penalty on ExxonMobil on Thursday for alleged violations of U.S. sanctions on Russia. Specifically the allegations were that during a narrow, 9-day window in May 2014, the U.S.-based oil giant entered into several contracts with Russian energy…

I’m proud of my firm and my team’s big win that came out yesterday in a major, widely-watched sanctions case at the U.S. Court of Appeals for the District of Columbia Circuit. Read our last alert to see why win…

Like other areas, developing compliance with anti-corruption regulations is a tall endeavor whose requirements can vary based on a number of factors, including jurisdiction, size, and sophistication of the company.  The emerging International Standards Organization (ISO) 37001:2016 standard for Anti-Bribery…

Chalk this one up as one more sign of how granular U.S. sanctions on Iran still are and why you should still be careful. We recently helped a client obtain an OFAC license to close out a bank account in…

One morning in February I woke up to see an email from someone at the University of Copenhagen’s Faculty of Law inviting me to speak at a conference there titled “The Impact of the Nuclear Agreement with Iran,” to be…

This heading is perhaps a bit more exciting than it should be, but maybe that’s necessary given the tone of the White House this week towards Iran, following that country’s recent missile tests.  Two days after US National Security Advisor…

OFAC announced on Friday that the prohibitions in the Sudanese Sanctions Regulations, 31 CFR Part 538 (the “SSR”) will be effectively narrowed (not repealed!) via a Final Rule issued Tuesday, January 17 in the Federal Register.  This is in response…

2017 has started and a new administration will be in the White House in less than three weeks. January 16 will mark exactly a year since implementation of the Joint Comprehensive Plan of Action (the “JCPOA”, also referred to commonly as…

Much has been said lately about the lack of sufficient banking channels between Iran and the rest of the world, and the spillover effects it is having on Iran’s international economic re-engagement.  The Joint Comprehensive Plan of Action (JCPOA), the so-called…