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Sanctions Targeting Iran

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Effective October 28, 2022, Canada implemented additional sanctions against Iran due to its “ongoing gross and systematic human rights violations and continued actions to destabilize regional peace and security.” An additional four individuals and two entities have been listed under Schedule 1 of the Special Economic Measures (Iran) Regulations (the “Regulations”). Generally speaking, listing under Schedule 1 of the Regulations imposes a dealings prohibition, effectively an asset freeze, against the listed person. Any person in…

On September 23, 2022, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued Iran General License D-2 (“GL D-2”), which amends and replaces the former Iran General License D-1 (“GL D-1”), and published three related Frequently Asked Questions (“FAQs”). GL D-2 authorizes a more expansive set of internet communication-related activities, including cloud-based software and services, that are otherwise prohibited under the Iranian Transactions and Sanctions Regulations (“ITSR”). According to the accompanying…

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 September 19, 2020, the US State Department issued a press release announcing the re-imposition of sanctions against Iran pursuant to the snapback process under UN Security Council Resolution 2231, the resolution that essentially terminated all UN sanctions on Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”). At the same time, the international community has rejected this unilateral US attempt to snapback UN sanctions. To implement the snapback of UN sanctions, on September…