Cross-Border Compliance Update

Cross-Border Compliance Update: March 2020

April 9, 2020

Foley Hoag’s Trade Sanctions & Export Controls Practice offers experienced, proactive regulatory advice to help clients avoid regulatory compliance missteps and to prevail in official proceedings. For more information about global compliance, visit the Foley Hoag Trade Sanctions & Export Controls Practice Group.

Included in this Issue:

  • Latest in Iran Sanctions
    • COVID-19 and Compliance: OFAC Releases New Iran-Related FAQ
    • Further Sanctions on Iranian Petrochemical Industry
  • Nicaraguan National Police Sanctioned
  • Settlement Agreement for Société Internationale de Télécommunications Aéronautiques SCRL (SITA)
  • Proposed Rules Set New CFIUS Fees
  • CFIUS Mandates Divestment of Hotel Software Company from Beijing Shiji Information Technology Co.
  • Department of Justice Update: Iran-Related Conviction; Extradition
    • Conviction for Sanctions Evasion through $115 Million Money Laundering Scheme
    • Iranian National Extradited for Exports of Military Items to Iran/p>
  • New Designation in Response to Violence in Northern Syria
  • Sanctions Target Mexican Businesses Linked to Drug Cartels
  • New CFIUS Real Estate Mapping Tool Released


Latest in Iran Sanctions

COVID-19 and Compliance: OFAC Releases New Iran-Related FAQ

The impact of COVID-19 on sanctions is still developing, but on March 6, 2020, OFAC released a new FAQ on humanitarian assistance to Iran related to fighting the global pandemic. FAQ 828 sets forth guidance for how to provide medical assistance and humanitarian donations to Iran in compliance with U.S. sanctions. One important reminder is that an actions taking place under General License E, which allows NGOs to engage in certain nonprofit activities with Iran, must be undertaken by the NGO itself, and not directly by U.S. individuals. For more information, see the FAQ here.

Download the March 2020 Foley Hoag Cross-Border Compliance Update (pdf).