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First, do no harm…

The old Will Rogers saying goes, “when you find yourself in a hole, stop digging”. Unfortunately, American Optisurgical didn’t know that saying. OFAC just released the settlement with American Optisurgical today. They got penalized for 36 export violations of unlicensed medical equipment to Iran, in violation of the ITSR (Iranian […]

Word of the day: U-turn payment

First things first: The exemption for U-turn payments from OFAC’s Iran sanctions program was discontinued in 2008. So, what was the U-turn? As a technical matter, payments that were originated by a non-Iranian bank and destined for a non-Iranian bank were excluded from the Iranian sanctions program. According to a […]

HMT issues new guidance on Iranian sanctions

Her Majesty’s Treasury has issued new guidance on the Iranian sanctions program due to the replacement of regulations on January 31st, due to some new EU regulations. Unfortunately, the press release neither says much specific on it, nor links to anything particularly useful. Except for this: there are certain payments […]

OFAC Designation Updates for February 6, 2013

Now that the TRA changed today (see the previous post), OFAC has to designate someone… ZARGHAMI, Ezzatollah (a.k.a. ZARGHAMI, Ezatollah); DOB 1959; POB Dezful, Khuzentan Province, Iran; Title Director, Islamic Republic of Iran Broadcasting (individual) [IRAN-TRA]. IRANIAN COMMUNICATIONS REGULATORY AUTHORITY (a.k.a. “SAZMAN-E TANZIM MOGHARARAT”), Ministry of Information and Communications Technology, […]

February 6, 2013: OFAC Guidance Updates

Today, OFAC issued two new guidance documents, both relating to the Iranian sanctions regulations and licenses. The first is a new Frequently Asked Questions (FAQ) document relating to the Iran Threat Reduction and Syria Human Rights Act of 2012 (aka “TRA”). In particular, the FAQ speaks to Section 504 of […]

The next frontier is already here

You may or may not have heard of Bitcoin, but people who are looking to perpetrate financial crimes are discovering it. Bitcoin is a decentralized virtual currency that enables anonymous peer-to-peer transactions without any controls or accountability to any central authority. Long story short, a story in Bloomberg Businessweek in […]

India not all in on Iran

A short news item in the Times of India notes that in the Congressional Research Service’s (CRS) report on Iran, it was noted that, while India is implementing the UN sanctions against Iran, it’s dragging its feet on going beyond that and also matching the stricter sanctions imposed by the […]