Erich Ferrari August 23, 2018 They’re Ba-ack….JCPOA Withdrawal Nearing Completion with E.O. 13846 There have been so many questions waiting to be answered since the U.S. announced that they would be withdrawing from…
Tyler Cullis August 28, 2017 Is OFAC’s Application of Its Iran Export Ban Reasonable? The Case of COSL Singapore Ltd. On August 24, 2017, OFAC announced a settlement agreement with COSL Singapore Ltd. for apparent violations of the ITSR stemming…
Tyler Cullis August 17, 2017 OFAC Settlement Agreement with IPSA Highlights Needs to Reconsider Licensing Policies On August 10, 2017, OFAC announced a settlement agreement with IPSA International Services, Inc. (IPSA), a U.S. company, for apparent…
Tyler Cullis July 30, 2017 OFAC Designates Four Iranian Ballistic Missile Entities On July 28, 2017, OFAC designated four Iranian entities owned or controlled by Shahid Hemmat Industrial Group , an Iranian…
Tyler Cullis July 23, 2017 Can Trump Leave the Iran Nuclear Agreement? The Trump administration reportedly came close to de-certifying Iran's compliance with the JCPOA. If it chooses to do so in…
Tyler Cullis May 19, 2017 Have We Entered a New Phase of Iran Sanctions? Some allege that the Trump administration is taking a more punitive approach towards Tehran.
Tyler Cullis March 28, 2017 Does New Senate Bill Designate IRGC a Terrorist Group? The answer is more complicated than might be expected.
Tyler Cullis March 6, 2017 Is There a “Policy Gap” in IRGC Sanctions? Is there a "policy gap" regarding U.S. sanctions targeting the IRGC and its designated agents or affiliates? Proposed legislation seems…
Tyler Cullis February 22, 2017 So You Want to Reside in Iran? If a U.S. person is interested in moving to Iran on a permanent basis, can that U.S. person open a…
Tyler Cullis February 10, 2017 IRGC Sanctions: A (Brief) History Reports indicate that the Trump administration is considering the promulgation of an Executive Order that would direct the Secretary of…