• Iran: The Sanctions Collapse Myth
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    Today’s debate over an interim nuclear deal with Iran is rightly focused on the size and scope of sanctions relief Tehran will receive in exchange for temporarily halting its nuclear activities. One widely circulated argument against such a deal is that the attraction of Iran’s market, rendered largely off-limits due to sanctions, is such that companies will attempt to secure Continue Reading...
  • OFAC’s Summer of Surprises
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    The Treasury Department’s Office of Foreign Assets Control (OFAC) is primarily known for its role as the agency charged with enforcing Iran sanctions. This summer, however, the agency came out with a series of actions aimed at mitigating the effect of sanctions on the Iranian people. Most recently, OFAC has issued two new general licenses authorizing certain humanitarian related activities Continue Reading...
  • Do As We Say, Not As We Do
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    Does the U.S. expect Iran to capitulate to sanctions in a way it would not? As the international community awaits the next round of P5+1 negotiations with Iran over its disputed nuclear program, the utility of U.S. sanctions and the parameters of a potential diplomatic agreement are the subject of intense debate. Past U.S. experience as a sanctions target suggests Continue Reading...
  • David Cohen’s Subtle, But Much Needed, Cry For Help
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    During Tuesday’s Senate Banking Committee hearing on Iran sanctions, New Jersey Senator Robert Menendez asked TFI Undersecretary David Cohen a question which has been on our minds for a while now. “We keep adding sanctions regimes, which we need to… Do you have the wherewithal, the resources, to continue to pursue the sanctions regime we want, b/c if I give Continue Reading...
  • A Sanction For (Almost) Every Reason
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    I suppose the President has gotten tired of Congress getting all of the attention when it comes to imposing new sanctions on Iran. Earlier this week, he issued a new executive order implementing certain sanctions that were previously called for in the Iran Freedom and Counter Proliferation Act (IFCA) and adding some new sanctions of his own. Here are the highlights: 1) Continue Reading...
  • Effect of Eased Iran Communication Restrictions May Take Time
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    In a move alluded to earlier this week by Undersecretary of State for Political Affairs Wendy Sherman, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) has released General License D, authorizing the exportation and re-exportation by US persons to Iran of services, software and hardware incident to the exchange of personal communications. According to the Continue Reading...
  • Talking North Korea Sanctions with PIIE’s Stephan Haggard
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    While North Korea has seemingly gone quiet again following several months during which tensions on the peninsula rose to dangerous levels, the Hermit Kingdom remains one of the United States’ most intractable foreign policy challenges. We posed some questions to Peterson Institute for International Economics fellow Stephan Haggard in order to explore the role sanctions play in U.S. efforts to address Continue Reading...
  • Poor Advisers: Online Travel Agencies Misinterpret OFAC Regulations
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    As sanctions have increased over the years, planning a trip to Tehran has gotten progressively more difficult. A brief review of a number of popular online travel booking services bears this out, as each site has a different method of refusing to secure flights to Iran. A search for flights between Washington, D.C.’s Dulles airport and Imam Khomeini Airport in Continue Reading...
  • EU Notably Silent after US Sanctions Greek National
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    If an international agreement is violated and no one makes a sound, did it really happen? A few weeks ago, the State Department imposed sanctions on Greek businessman Dimitris Cambis and his company, Impire Shipping Ltd., pursuant to the Iran Sanctions Act of 1996 (ISA), for his role in operating what Treasury Under Secretary for Terrorism and Financial Intelligence David Continue Reading...
  • Iran Sanctions Relief: What it Means
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    As negotiations in Almaty, Kazakhstan, entered their first day, Al-Monitor’s Laura Rozen has reported that the P5+1 plans to offer Iran sanctions relief in a number of different areas in exchange for shutting the underground Fordow enrichment facility, ending 20% uranium enrichment, and shipping out its existing 20% stockpile. While previous leaks had only mentioned easing restrictions on using gold Continue Reading...
  • Bad Sanctions: Who’s to Blame?
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    I was recently re-reading the Judicial Review Commission Report on Foreign Assets Control (“Report”), a 2000 report on the implementation of the Foreign Narcotics Kingpin Designation Act (“Kingpin Act”). A few key points from that Report got me thinking about the overall state of U.S. economic sanctions and where some of the more onerous provisions arise from. While most people Continue Reading...
  • Setting the Record Straight on Hagel, Iran Sanctions
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    Since the announcement that President Barack Obama would nominate former Nebraska Sen. Chuck Hagel as Secretary of Defense, many have pointed to his past opposition to some Iran sanctions legislation as evidence that, in the words of Sen. John Cornyn (R-Texas), he “does not fully appreciate the dangers of a nuclear Iran or the character of the Iranian regime.” In an ad paid for Continue Reading...
  • New Sanctions on Iran and Neo-Big Stick Diplomacy
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    Contained in the Defense Authorization Act (NDAA) of 2013, and signed into law by President Obama on January 2, are sweeping new sanctions targeting Iran over its disputed nuclear program. The new measures target foreign entities engaging in a wide array of transactions with Iran, including the sale of any goods supporting Iran’s energy, shipping and shipbuilding sectors, the sale Continue Reading...
  • OFAC Starts Off 2013 With An Enforcement Action
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    On the first business day of the new year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $191,700 settlement of sanctions violations with Ellman International, Inc. (“Ellman”) for apparent violations of the Iranian Transactions Regulations (“ITR”). Under it’s prior ownership and management Ellman exported products to Iran and retained the services of an Continue Reading...
  • Light at the End of the Tunnel? Where are Iran Sanctions Going?
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    If there is one thing that politicians in Washington consistently agree on it is additional sanctions on Iran. In the past year there have been numerous sanctions issued against Iran. Those sanctions have been at least partially responsible for a rapid devaluation of Iran’s currency, the Rial. Many of the sanctions imposed in the past year have targeted Iran’s financial Continue Reading...
  • The Upward Spiral: A Timeline of HSBC’s Iran Sanctions Violations
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    Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), announced their second massive penalty of the week when it was made public that HSBC was remitting $375 million dollars to settle allegations that HSBC, through its U.S. subsidiary, HSBC USA (HBUS), violated OFAC sanctions targeting Iran, Burma, Sudan, Cuba, and Libya. A large portion of Continue Reading...
  • Looking back at a year of Iran Sanctions
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    This was a big year for sanctions. Although 2012 isn’t over yet and there is some pending legislation threatening to impose more sanctions against Iran and a forthcoming set of regulations from OFAC on some of the additional Iran sanctions we saw in the late summer/early fall, I thought I would recap some of the big sanction developments of 2012. Continue Reading...
  • Iranian National and U.S. Citizen Plead Guilty to Iran Sanctions Violations
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    Yesterday, two individuals, Hamid Asefi and Behzad (Tony) Karimian pleaded guilty to violations of the Iranian Transactions and Sanctions Regulations (ITSR) as promulgated pursuant to the International Emergency Economic Powers Act (IEEPA). The charges stem from their involvement in the unlawful export of aircraft and aircraft parts from the United States to Iran without a license from the United States Continue Reading...
  • Despite Looser Rules, Medicine Still Not Flowing to Iran From US
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    As sanctions over Iran’s disputed nuclear program have intensified over the past year, reports have documented the deteriorating humanitarian situation in Iran. Medicine, in particular, is in  short supply across the country, with drugs produced in the United States and European Union the most difficult to find. Currently, Iranian authorities are blaming the international sanctions for the death of 15-year-old Continue Reading...
  • US Loosens Sanctions On Medicine Sales to Iran
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    While most Americans and the US foreign policy elite were focused on last week’s final presidential debate, a small office within the US Treasury Department, without fanfare, rewrote regulations governing key aspects of the Iranian sanctions....