OFAC's New Iran Sanctions May Not Signal Seismic Change

Law360 (January 14, 2020, 6:09 PM EST) -- On Jan. 10, President Donald Trump signed an executive order,[1] titled "Imposing Sanctions with Respect to Additional Sectors of Iran," to follow through on his Jan. 8 promise of "additional punishing economic sanctions on the Iranian regime" in the wake of Iran's bombing of two Iraqi military bases.[2]

The executive order, which follows a period of upheaval in U.S.-Iran relations, strengthens U.S. sanctions against Iran by expanding the ability of the U.S. Department of the Treasury's Office of Foreign Assets Control, or OFAC, to sanction non-U.S. entities that transact with, or process payments on behalf of, Iran.

The U.S. government has...

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