Iranian Sanctions Compliance

U.S.-Iranian relations have proven extremely volatile in recent years. For example, the Joint Comprehensive Plan of Action (JCPOA) nuclear agreement between Iran and the P5+1 powers (including the United States) was signed on July 14, 2015, and on January 16, 2016, the United States removed over 400 individuals and entities from OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), the Foreign Sanctions Evaders List (FSE List), and/or the Non-SDN Iran Sanctions Act List (NS-ISA List), including the Central Bank of Iran (CBI) and specified Iranian financial institutions. Yet, so-called “secondary sanctions” (sanctions on foreign firms) that have been imposed because of Iran’s support for terrorism, its human rights abuses, and its illicit missile program largely remained in place. Most sanctions that apply to U.S. persons and corporations, including regulations barring transactions between U.S. and Iranian banks, also remained in effect.


Following the election of Donald Trump as president in 2016, the U.S. government pursued a “maximum pressure” policy – reinstating all sanctions against Iran and adding additional measures to bar Iran from access to the global financial system and global oil markets. Most notably, the U.S. government designated the Islamic Revolutionary Guard Corps as a Foreign Terrorist Organization, thereby indirectly sanctioning a substantial portion of the Iranian economy. That designation has been placed into doubt by the Biden Administration’s efforts to negotiate the United States’ re-entry into the JCPOA and most informed analysts expect the U.S. to withdraw many significant sanctions as part of that re-entry process.


Osen LLC’s team has extensive experience with U.S. regulations and statutes affecting international businesses in sanctions, terror-financing and anti-money laundering reviews. Osen LLC has investigated and analyzed potential violations in this regulatory space and advises governments and private parties on the application of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) and related Iranian sanctions laws, regulations and executive orders. These include the Iran Threat Reduction and Syria Human Rights Act of 2012, the Iranian Freedom and Counter-Proliferation Act of 2012, the Iranian Transaction Regulations, and other laws and sanctions regimes enacted by the United Nations, the European Union, and other jurisdictions against Iran.


Sanctions have been a component of U.S. policy concerning Iran since 1979. Some U.S. sanctions have been enacted into law, others have been imposed via Presidential Executive Order (often under the “International Emergency Economic Powers Act”), and still others are predicated upon legally authorized administrative determinations (including sanctions resulting from the U.S.’s designation of Iran as a “State Sponsor of Terrorism”). CISADA, which amended the Iran Sanctions Act, significantly ratcheted up the scope and reach of the existing sanctions regime prior to JCPOA.


While European sanctions have been largely removed and U.S. policy toward Iran remains in flux, tracking and analyzing sanctions risks requires extensive knowledge of this evolving legal framework and specialized knowledge concerning Iranian efforts to evade U.S. sanctions.


Osen LLC’s team does more than assess specific transactions or analyze the dry language of statutes, regulations, and resolutions: We track and map trends and identify risks posed by continued Iranian sancti