All tagged OFAC

Political Risks Outweigh Legal Impact of IRGC Terrorism Designation

◢ The Trump administration announced the designation of the Islamic Revolutionary Guards Corps (IRGC)—a branch of Iran’s armed forces—as a Foreign Terrorist Organization (FTO) pursuant to section 219 of the Immigration and Nationality Act (INA). While the practical effect of the FTO designation is negligible at best, the risks to the US from the designation could be severe.

Here’s How the United States Can Help Iran's Flood Recovery

◢ In order improve preparedness for frequent earthquakes, floods, sandstorms, and heat-waves, Iran urgently needs to upgrade its surveying and monitoring technologies to better model and predict meteorological, hydrological, and geological events. The United States should create a new general license to remove the sanctions-related barriers to Iran’s acquisition of these much needed technologies.

Parsian Bank CEO: US Treasury Made ‘Mistake’ in Iran Sanctions Designation

◢ In an exclusive interview with Bourse & Bazaar, CEO of Iran’s Parsian Bank, which was sanctioned last week by the US Treasury, has described the designation of the bank as a Specially Designated Global Terrorist (SDGT) a “mistake.” The move against one of Iran’s leading private sector banks by has many in Iran’s banking sector worried about the ongoing viability of humanitarian trade.

Under Trump, US Sale of Medical Goods to Iran Down Nearly 40%

◢ With just two weeks until Trump reimposes secondary sanctions on Iran, administration officials are under increasing pressure to prove that the returning sanctions will not adversely impact humanitarian trade. Looking to US Census Bureau export data, a clear pattern emerges—the export of humanitarian goods like food and medicine remains significantly lower than average monthly values registered during the Obama years.

Bankless Task: Can Europe Stay Connected to Iran?

◢ With US sanctions on Iran’s banking sector due to come into effect soon, European countries are now considering measures that would facilitate trade transactions with Iran through a new legal and institutional structure. European governments have been reviewing this legal entity, known as a Special Purpose Vehicle (SPV), for months. The timing of this public announcement suggests that they have a degree of confidence that the SPV can become operational, and that Europe can use the model to showcase its ability to deliver on its commitments.

Iran: The Case for Protecting Humanitarian Trade

◢ A crisis is looming in Iran’s healthcare sector: patients are reporting shortages in life-saving medicine. The situation is expected to worsen once US sanctions on Iran are reimposed in November. European and US companies that can provide the advanced medicine and equipment needed to treat chronic diseases inside Iran are grappling with how to sustain their operations. New US sanctions will put the health of ordinary Iranians at risk. Europe can take concrete steps to minimize this—steps which also support its ongoing commitment to the nuclear deal.

US Officials Warn of ‘Deceptive Web’ of Iran Business, But Hamper Transparency Efforts

◢ In a recent speech, Under Secretary of the Treasury Sigal Mandelker warned that foreign companies that maintain a presence in Iran must conduct “extra due diligence to keep them from being caught in Iran’s deceptive web.” But background conversations with several compliance specialists reveal that US sanctions are a major barrier to key AML/CTF reforms in Iran. Industry-standard compliance software is not accessible for Iranian end users, leaving some experts to conclude that Iran is being “set up to fail.”

New US Sanctions Target Operator of Iran's Presidential Aircraft

◢ The US Treasury Office of Foreign Asset Control on Thursday announced a new round of targeted sanctions designations, including sanctions on Dena Airways, the company which operates the Iran’s presidential aircraft used by Hassan Rouhani for official travel. The new sanctions follow the designation of Iran’s central bank governor, Valliollah Seif, and reflect a further targeting of the Rouhani administration.

Ambiguity in Trump Sanctions Could Put Humanitarian Trade with Iran at Risk

◢ In the years when Iran was under broad international sanctions, the country saw shortages in key foodstuffs and life-saving medicines. Despite attestations to the contrary, international sanctions hurt the Iranian people in cruel ways. As Iranians prepare for the return of U.S. sanctions, concerning ambiguity in OFAC’s new sanctions guidance may undermine the longstanding exemptions for humanitarian trade and the carve-outs for the Iranian banks which facilitate these sales.

U.S. Sanctions on Iran Set to Return: A Simple Explainer

◢ On 8 May 2018, U.S. President Trump announced that the United States “will withdraw from the Iran nuclear deal” and that the United States “will be instituting the highest level of economic sanctions”. At the same time, U.S. authorities announced that U.S. sanctions would be re-instated, at the latest by 4 November 2018. What does this mean for companies who have ties to Iran or who do business in Iran?

Iran Air Expands Routes Amid Uncertainty

◢ Despite recent uncertainty surrounding the 2015 nuclear deal, Iran Air has been moving forward with its expansion efforts, drastically changing its face in the airline industry.

◢ Iran Air's network has grown significantly since 2015, but remains much smaller than that of a decade ago. In 2002, the airline was serving 18 European destinations, compared to today’s 13 destinations.

American Medical Company Second Sight Enters Iranian Market

◢ Second Sight has entered the Iranian market with two procedures in Shiraz. Patients were implanted with the Argus II system, which provides an artificial form of useful vision to those suffering from degenerative loss of sight. 

◢ The company entered into a partnership with Iranian firm Arshia Gostar Darman in 2016 and holds a license from the U.S. Department of Treasury that permits the sale of its devices Iran. 

Iran Sanctions Policy Increasingly Throttles Free Trade in Ideas

◢ Since 1988, the Berman Amendment has limited the authority of the President to restrict the exchange of information as part of American sanctions policy. 

◢ But the new sanctions designation of the IRGC and recent voluntary actions by American companies suggest that the long standing protection for the free trade of ideas is under threat, as OFAC seems less willing to provide clear protections. 

Boeing, Iran, and American Jobs

◢ The first new Boeing jetliner is likely to be delivered to Iran Air later this month in what will a historic moment for US-Iran relations. 

◢ Boeing's deal with Iran Air represents a unique instance in which an American company's exports to Iran directly support American jobs. This simple fact may provide a framework on which US-Iran ties could be stablizied during the course of the Trump administration.

A Swedish Training Program May Hold the Answer to Iran’s Banking Challenges

◢ Iran's inability to link with the European banking system stems in part from a lack of capacity in key governance and compliance functions. 

◢ In the 1990s, European governments launched substantial "training and technical assistance" programs to help post-Communist states raise standards. Iran needs similar programs, and a model from Sweden may be the most effective.