The month of September 2023 saw an increase in enforcement actions in the sphere of international trade, particularly concerning Iran. Notably, the Office of Foreign Assets Control (OFAC) announced settlements with two prominent entities, 3M and Emigrant Bank, both accused of contravening the Iranian Transactions and Sanctions Regulations (ITSR).
In addition to corporate indictments, individuals have also faced repercussions for violating sanctions. Highlighting this, a Virginia man was convicted under the International Emergency Economic Powers Act (IEEPA) and ITSR for sending heavy construction equipment to Iran.
Moreover, the Department of Justice (DOJ) publicly finalized its first recorded criminal resolution case relevant to these regulations. Although the specifics of this resolution remain under wraps, it marks a firm step in the DOJ’s enforcement actions in the international trade arena.
This extensive enforcement action by both OFAC and the DOJ represents a marked emphasis on ensuring compliance with international trade regulations and sanctions laws, especially regarding Iran. Legal professionals operating internationally, particularly those working within trade agreements and regulations, would be well-advised to note these developments and adjust compliance strategies accordingly.
For more detailed analysis and consequences of this month’s international trade enforcement actions, consider consulting the full report provided by Bass, Berry & Sims PLC.