Iran-a-palooza
Lots of news lately on Iran sanctions, so here’s a summary and some links. Here’s a link to the OFAC letter we mentioned last week disputing some of the charges made by the New York State Department of Financial Services…
Category Iran Sanctions
New Law Eliminates Foreign Sub Loophole in Iran Sanctions
The just-passed Iran Sanctions, Accountability, and Human Rights Act of 2012 for the most part merely decorates the Iran sanctions cake with a few more sprinkles and cherries, but one provision is likely to have a significant impact, namely the…
OFAC to UK: NYDFS Misread Our Rules
Yesterday, I reported on the New York Department of Financial Services’ Order against Standard Chartered claiming that the Bank violated the rules of the Office of Foreign Assets Control by stripping out the names of Iranian entities in wires for…
You Won’t Like Me When I’m Angry
Here’s a good rule of thumb: Write all emails as if the distribution list included the entire planet because you never know when any given might come back to haunt you. If a certain executive at Standard Chartered had followed…
Stupid Quote of the Day
Ahem. Here is what Nahal Iravani-Sami, president of the Iranian American Bar Association, has to say about whether retail clerks at Apple Store should sell items to customers even if it is disclosed they plan on illegally exporting those items…