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US Sanctions against Iran

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On May 14, 2020, the US Department of State, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the US Coast Guard issued guidance to the private sector aimed at preventing deceptive shipping practices used in sanctions evasion, smuggling, facilitation of terrorism, and other criminal activity (the “Advisory”).  The Advisory focuses on tactics recently used by malign actors to evade sanctions and sets out a non-exhaustive list of best practices companies…

In a judgement of 7 April 2020 (ECLI:NL:HR:2020:623), the Dutch Supreme Court confirmed that the EU Blocking Regulation (“EUBR”) does not prevent extradition of an Iranian national to the United States for their alleged involvement in US export controls and sanctions violations. With this judgement, the Supreme Court upheld the judgement of the District Court of Rotterdam of 5 July 2019 (ECLI:NL:RBROT:2019:5338).   This case was triggered by an extradition request for an Iranian national…

On 31 March 2020, the UK Foreign and Commonwealth Office (“FCO”) announced that the Instrument in Support of Trade Exchanges (INSTEX) had successfully concluded its first transaction. This transaction involved the successful export of medical goods from Europe to Iran, and paves the way for future transactions. In its announcement, the FCO stated: “Now the first transaction is complete, INSTEX and its Iranian counterpart STFI [(Special Trade and Finance Instrument)] will work on more transactions…

On January 16, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) released a new frequently asked question (“FAQ”) regarding Iran-related sanctions. This FAQ comes on the heels of the US Government’s recent issuance of Executive Order 13902 (“EO 13902”) on January 10, 2020, which expanded secondary sanctions to target the Iranian construction, mining, manufacturing, and textile sectors and those parties engaged in “significant transactions” or providing “material support” to any parties designated…