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Ryan Poitras

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On October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) identified the Iranian financial sector as subject to Executive Order (“EO”) 13902 and, based on such identification, designated 18 Iranian banks.  Our previous blog post on EO 13902 is available here.  OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below.  The action represents a significant escalation of the sanctions targeting Iran’s financial sector, yet many…

On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published four Frequently Asked Questions (the “FAQs”) regarding Iran-related sanctions under Executive Order 13902 (“EO 13902”). EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in “significant transactions” or providing “material support” to parties designated pursuant to the order. Our blog post regarding EO 13902 is available here. The FAQs…

On May 1, 2020, the Trump Administration issued Executive Order 13920 on “Securing the United States Bulk-Power System” (“Bulk-Power System EO”), which aims to prevent “foreign adversaries” from exploiting vulnerabilities in the US bulk-power system in furtherance of US national security. As explained in further detail in the press release concurrently published by the Department of Energy, the Bulk-Power System EO is meant to prohibit certain transactions involving bulk-power system equipment where the Secretary of…

On April 16, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Fact Sheet providing a helpful consolidated summary of the various existing exemptions, exceptions, and authorizations relating to the provision of humanitarian assistance that are available under certain U.S. sanctions programs to leverage in response to the COVID-19 pandemic. Separately, on April 20, 2020, OFAC issued a notice encouraging the prompt communication to OFAC of concerns over potential delays in…