Increasingly Complex Iranian Sanctions Regimes Cause Ongoing Complications for Compliance Suites

May 17, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

Since the international community decided to implement a plan to reduce sanctions against Iran, formally known as the Joint Comprehensive Plan of Action (JCPOA), on January 16, 2016 (“Implementation Day”), the European and U.S. regimes have become increasingly misaligned. Not surprisingly, this has led to compliance officers and other professionals having to navigate extremely treacherous waters. In a recent poll conducted by Sanctions Alert, when attendees were asked what the prospects are that U.S. sanctions will be eased in the near future, almost 90% of those polled indicated that this was either “Unlikely” or “Very Unlikely”. (more…)

Trump Administration Certifies Iran’s Compliance with Nuclear Deal, but Initiates Review of Sanctions Relief

April 21, 2017
By: Anthony Rapa*

Will the Trump Administration “waive” goodbye to sanctions relief under the Iran nuclear deal?

Last night, Secretary of State Rex Tillerson certified to Congress that Iran is in compliance with the Joint Comprehensive Plan of Action (JCPOA) agreement regarding Iran’s nuclear program, but signaled that the Trump Administration is reviewing whether continued sanctions relief under the JCPOA would be appropriate.  Secretary Tillerson’s communication is set out in a letter to House Speaker Paul Ryan and summarized in a Reuters article. (more…)

New Sanctions Imposed against Iran by Trump Administration Signal Further Decline in U.S.-Iran Relations

March 31, 2017

On March 21, the US government imposed new sanctions against a group of 11 entities and individuals for transferring technology and sensitive items to Iran’s ballistic missile program under the Iran, North Korea and Syria Nonproliferation Act (INKSNA). This piece of legislation authorizes the U.S. to impose sanctions against foreign individuals, private entities, and governments that engage in the proliferation of equipment and technology from Iran, North Korea, or Syria,controlled under multilateral control lists (such as the Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement). INKSNA also provides for sanctions for the transfer of equipment or technology having the potential to make a material contribution to the development of weapons of mass destruction or ballistic missile systems. (more…)

Waive it Goodbye? How the Trump Administration Might Attack the JCPOA

February 4, 2017
By Anthony Rapa*

President Trump has made no effort to conceal his disdain for the Joint Comprehensive Plan of Action (JCPOA) agreement regarding Iran’s nuclear program, which he frequently has described as a “disaster” ranking among the worst deals in U.S. history. However, heated rhetoric notwithstanding, he often spoke on the campaign trail of improving the deal, rather than tearing it up. While the Administration has not yet advanced any specific policy regarding the JCPOA, and while future developments remain difficult to predict, the President may seek to ramp up pressure on Iran within the framework of the existing agreement, rather than repudiate the deal altogether. As the President himself explained when he was a candidate: “We have a horrible contract, but we do have a contract.” (more…)

Trump Sanctions Policies Still Undefined, But Could Affect Many Nations and Compliance Officers – Part 3: Steven Bannon’s “America First” Agenda Looms As Big Factor

January 31, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

In this series, we present the comments and assertions made by President Donald Trump and his top assistants concerning economic sanctions and export controls so compliance professionals can make informed decisions as to the likely positions of the new U.S.administration in the next four years. (more…)