Lise S. Test


The United States has imposed additional sanctions on Iran in the wake of Iran’s missile strike on military bases in Iraq. On January 10, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had added 8 senior Iranian government officials and 17 Iranian metals producers and mining companies to the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, President Trump issued a new Executive Order, “Executive Order on Imposing Sanctions with Respect to Additional Sectors of Iran” (the “Order”), authorizing the imposition of secondary sanctions on certain transactions involving the construction, mining, manufacturing, and textiles sectors of the Iranian economy.

On December 11, 2019, the US State Department announced the designations of the Islamic Republic of Iran Shipping Lines (“IRISL”), its China-based subsidiary, E-Sail Shipping Company Ltd (“E-Sail”), and Mahan Air, a privately-owned airline based in Tehran, under Executive Order 13382 (“E.O. 13382”), for their involvement in the transporting of weapons of mass destruction (“WMD”).  All three entities had previously been designated to the Specially Designated Nationals and Blocked Persons List (“SDN List”) administered by US Treasury Department’s Office of Foreign Assets Control (“OFAC”). OFAC will implement the new designations by adding the [NPWMD] and [IFSR] tags to the SDN List entries of IRISL and E-Sail effective June 8, 2020. OFAC updated the Mahan Air entry effective immediately. OFAC published two related Frequently Asked Questions, FAQs 810 and 811.

Effective November 18, 2019, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule extending by 90 days through February 16, 2020 the validity of the Temporary General License (“TGL”) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations to Chinese-headquartered Huawei Technologies Co. Ltd. (“Huawei”) and one hundred and fourteen of its non-US affiliates designated on the BIS Entity List. The TGL…

On October 23, 2019, the US Treasury Department Office of Foreign Assets Control (“OFAC”) announced that it had deleted two Turkish ministries and three Turkish individuals from the list of Specially Designated Nationals and Blocked Persons (“SDN List”). These five parties had been designated to the SDN List on October 14, 2019 pursuant to Executive Order 13894 (“EO 13894”) for contributing to Turkey’s military offensive in northern Syria. Please see our blog post regarding EO 13894 here.

OFAC’s removal of these parties from the SDN List followed a statement from President Trump that he had instructed the Secretary of the Treasury to lift all sanctions imposed on Turkey on October 14th in response to the Government of Turkey’s agreement to adhere to a permanent ceasefire. President Trump indicated that sanctions targeting Turkey would be lifted, “unless something happens that we’re not happy with.” There are no remaining SDNs designated pursuant to EO 13894. The executive order itself remains in effect, however, thus providing the Secretary of Treasury with ongoing authority to designate individuals or entities under EO 13894.