Dj Wolff

Blogs: Data Law Insights, Government Contracts Legal Forum, International Trade Law, Retail & Consumer Products Law Observer

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International Trade Law

Escalating Tensions in the Middle East: U.S. and EU Sanctions Developments on Iran

By Carlton Greene, Michelle Linderman, Jeff Snyder, Dj Wolff, Nicole Succar, Erik Woodhouse & Nimrah Najeeb

January 15, 2020

Keeping pace with the rapidly changing geopolitics in the region, the last week has brought a series of Iran-related sanctions developments with which global businesses need to keep up. First, on January 10, the United States further escalated sanctions against Iran, creating new designation authorities for those “operating in” Iran’s construction, mining, manufacturing, and textile sectors under Executive Order 13902 (“EO 13902”). These new measures come amidst the recent escalation of conflict between the U.S.…

International Trade Law

District Court Overturns OFAC’s $2 Million Fine Against Exxon Mobil

By Carlton Greene, Michelle Linderman, Jeff Snyder, Dj Wolff, Nicole Succar & Erik Woodhouse

January 7, 2020

On December 31, 2019, a federal district court in Texas (the “District Court, or “Court”) overturned a $2 million fine levied by the Office of Foreign Assets Control (“OFAC”) against Exxon Mobil Corporation (“Exxon”) for alleged violations of the Ukraine-Related Sanctions Regulations (“URSR”). OFAC had assessed that Exxon received a prohibited service from a designated person when it allowed Igor Sechin, a Specially Designated National (“SDN”), to sign eight contracts with Exxon in his official…

International Trade Law

Congress Passes New Russia and Venezuela Sanctions and Advances New Russia & Turkey Sanctions

By Dj Wolff, Jeff Snyder, Carlton Greene, Addie Cliffe, David Baron, Nicole Succar, Erik Woodhouse, Jana del-Cerro, Brian McGrath & Nimrah Najeeb

December 27, 2019

Dec.27.2019 As 2019 draws to an end, Congress has been busy on economic sanctions legislation. This includes passing new Russia-related sanctions and a Venezuela-related government contracts procurement restriction as part of the National Defense Authorization Act for Fiscal Year 2020 (NDAA 2020). The U.S. Senate Foreign Relations Committee has also approved two new pieces of legislation that would increase sanctions on Russia and Turkey, respectively. Full details on each of these developments are below the…

International Trade Law

New Sanctions Imposed on Elements in the Turkish Government

By Carlton Greene, Dj Wolff, Alan W. H. Gourley, Nicole Succar & Jana del-Cerro

October 21, 2019

On October 14, 2019, the Trump Administration followed through on its recent threats by issuing a new Executive Order (EO) (as yet unnumbered) establishing sanctions that effectively target the Turkish Government in response to the latter’s military intervention into Northern Syria. Using this authority, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) simultaneously added both the Turkish Ministry of Energy and Natural Resources and the Turkish Ministry of National Defence, as…

International Trade Law

Treasury Sanctions Iran’s Central Bank, Again

By Jeff Snyder, Dj Wolff & Nicole Succar

September 30, 2019

On September 20, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control designated the Central Bank of Iran, the National Development Fund of Iran, and the Etemad Tejarat Pars Co. under Executive Order 13224, OFAC’s counter-terrorism authority (E.O. 13224). The U.S. pointed to attacks on Saudi Arabia’s oil fields as the catalyst for this designation. With respect to the Central Bank of Iran’s counter-terrorism designation, OFAC finds that the Central Bank of Iran…

International Trade Law

OFAC Limits Cuba “U-Turn” Payments and Remittances

By Carlton Greene, Dj Wolff & Nicole Succar

September 13, 2019

On September 9, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published amendments to the Cuban Assets Control Regulations (the “Cuba Sanctions”) to limit “U-turn” transactions and remittances. “U-turn” transaction is a reference to a Cuba Sanctions authorization (31 CFR § 515.584(d)) for banking institutions subject to U.S. jurisdiction to process transactions prohibited by the Cuba Sanctions if the transaction originated and terminated outside the United States, and the originator and…

International Trade Law

United States Ramps Up Sanctions Pressure on Russia and Venezuela

By Dj Wolff, Carlton Greene, Nicole Succar, Jana del-Cerro & Erik Woodhouse

August 13, 2019

Over the course of the last week, the United States has escalated its sanctions programs targeting Russia and Venezuela. It began by implementing the long-delayed second round of sanctions on Russia mandated by the Chemical and Biological Weapons Act of 1991 (CBW Act) on Saturday, August 3, 2019. While the CBW sanctions will have a limited impact on most companies, the same cannot be said of the issuance of Executive Order 13884 (“E.O. 13884”) on…

International Trade Law

OFAC Sanctions 7 Companies, 5 Individuals for Involvement in Iran’s Nuclear Program

By Dj Wolff & Edward Goetz

July 19, 2019

On July 18th, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned seven companies and five individuals involved in the procurement of materials for sanctioned elements of Iran’s nuclear program. Based in Iran, China, and Belgium, these persons allegedly obtained items for Iran’s Centrifuge Technology Company (TESA), an entity previously designated by OFAC for its role in the proliferation of weapons of mass destruction. OFAC alleged that this network of companies and individuals…

International Trade Law

Trump Administration Follows Through on Plans to Tighten Cuban Sanctions

By Dj Wolff, David Baron, Mariana Pendas & Eduardo Mathison

June 6, 2019

On June 4, 2019, the Trump Administration formally implemented its previously announced intent to tighten its Cuban sanctions program. Specifically, on April 17, 2019 the Administration had announced that in response to Cuba’s alleged role in “destabilizing” activities throughout Latin America, particularly in Venezuela and Nicaragua, it would terminate aspects of the relaxations, primarily related to travel, previously implemented by the Obama Administration. Yesterday, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC)…

International Trade Law

OFAC Begins to Solidify Long-Awaited Guidance on Expected Elements for OFAC Compliance Programs

By Carlton Greene, Cari Stinebower, Dj Wolff & Dainia Jabaji

April 8, 2019

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is known for imposing hefty penalties for violations of US economic sanctions, with individual violations amounting to up to US $295,141 or twice the value of the transaction, whichever is greater, per prohibited transaction, and overall penalties sometimes running into the hundreds of millions, or even billions, of dollars. Despite this, OFAC historically has not provided much guidance for companies on the…

Dj Wolff

Escalating Tensions in the Middle East: U.S. and EU Sanctions Developments on Iran

District Court Overturns OFAC’s $2 Million Fine Against Exxon Mobil

Congress Passes New Russia and Venezuela Sanctions and Advances New Russia & Turkey Sanctions

New Sanctions Imposed on Elements in the Turkish Government

Treasury Sanctions Iran’s Central Bank, Again

OFAC Limits Cuba “U-Turn” Payments and Remittances

United States Ramps Up Sanctions Pressure on Russia and Venezuela

OFAC Sanctions 7 Companies, 5 Individuals for Involvement in Iran’s Nuclear Program

Trump Administration Follows Through on Plans to Tighten Cuban Sanctions

OFAC Begins to Solidify Long-Awaited Guidance on Expected Elements for OFAC Compliance Programs

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