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…

I was interviewed earlier this month by Al Jazeera Arabic on a particularly interesting issue concerning U.S. sanctions on Syria.  The question was whether a Skype appearance by a Syrian government official designated on the OFAC Specially Designated Nationals (SDN) list at a Washington,…

I was on Al Jazeera English tonight discussing the announcement of the implementation day of the Joint Comprehensive Plan of Action (JCPOA), the nuclear deal reached between Iran and the P5+1 (United States, United Kingdom, France, China, Russia, and Germany)…

We are all waiting for the IAEA to provide its certification on Iran’s nuclear energy program, which will be the cue for the P5+1 (the United States, United Kingdom, France, China, Russia, and Germany) to begin the process of sanctions…

While email notifications from OFAC are fairly regular to those of us who practice in the field, I don’t think I’ve ever received one on a Sunday night, particularly not a Sunday night preceding a federal holiday.  Tonight’s interestingly timed…

OFAC last Friday (September 18) announced certain amendments to the Cuban Assets Control Regulations, 560 CFR Part 515 (CACR) that expand the scope of activities with Cuba permissible for U.S. persons. While the bulk of the CACR remains firmly intact,…

I was on BBC Persian on Thursday, September 17, 2015 discussing the Iran nuclear deal and the phase in of sanction relief.  The interview was in Persian (Farsi).

OFAC released a periodic enforcement notice on July 29, 2015, this time about Massachusetts-based Blue Robin, Inc. for violating the Iranian Transactions and Sanctions Regulations (ITSR).  Blue Robin was fined $82,260 by OFAC for the violations. The allegations center around…

Following much anticipation, Iran and the P5+1 states (the United States, United Kingdom, France, Russia, China and Germany) announced on Tuesday morning Vienna time the reaching of a landmark deal on Iran’s nuclear deal. What does it include? The basic…

There has been a lot of guesswork regarding the potential (often assumed to be “certain”) unraveling of the international sanctions regime against Iran once it reaches an agreement with the so-called P5+1 (United States, United Kingdom, France, China, Russia and Germany). The…