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8/28/2026 12:54:48 PM

United States Reverses Course on Iran: From General License X to Operation Economic Outcast in Two Months

By Jacques Semmelman Alex San Martin

In yet another abrupt reversal of course with respect to Iran, the U.S. Department of the Treasury, at the direction of President Trump,...

8/26/2026 12:35:17 AM

The United States Removes Syria from the State Sponsors of Terrorism List

By Jacques Semmelman Alex San Martin

On August 24, 2026, the United States removed the designation of the Syrian Arab Republic (“Syria”) as a State Sponsor of Terrorism. The...

7/8/2026 6:45:27 PM

OFAC Issues General License X1, Withdrawing General License X's Grant of Broad Sanctions Relief on Iran's Oil and Petroleum Sector

By Jacques Semmelman Alex San Martin

The temporary trade opportunity created on June 22, 2026 by issuance of Iran General License X (GLX) by the U.S. Treasury Department’s...

6/23/2026 3:48:23 PM

OFAC Issues General License Authorizing Certain Transactions Incident and Necessary to the Sale, Delivery, or Offloading of Iran-Origin Crude and Petroleum Products

By Jacques Semmelman Alex San Martin

Recent events in the Middle East have resulted in a surprising turnaround in U.S. policy toward Iran. A June 17, 2026 MOU has started a...

4/20/2026 5:00:49 PM

The $166 Billion Question: What Importers Need to Know About the Tariff Refund Process

By Michael Rosensaft Jacqueline Perel

If your business imported goods subject to the now-invalidated International Emergency Economic Powers Act (IEEPA) tariffs, you may be...

4/1/2026 2:30:26 PM

OFAC Issues License Allowing Maduro’s Criminal Defense Counsel to Be Paid by Government of Venezuela, and then Revokes it

By Jacques Semmelman Alex San Martin

In a development that implicates the tension between the rights of criminal defendants to be represented by counsel of their choice, and...

3/19/2026 8:43:57 PM

The Evolving Landscape of Presidential Tariffs After the Supreme Court’s Decision in Learning Resources v. Trump

By Michael Rosensaft Caitlin Rubin

In February 2026, the Supreme Court ruled 6-3 in Learning Resources v. Trump that the International Emergency Economic Powers Act...

3/17/2026 10:49:36 PM

OFAC Issues General License Authorizing Certain Transactions Incident and Necessary to the Sale, Delivery, or Offloading of Russian-Origin Crude and Petroleum Products

By Jacques Semmelman Alex San Martin

On March 12, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License...

1/14/2026 3:13:59 PM

Serving as a Fiduciary for Sanctioned Clients? OFAC’s Recent Enforcement Action is a Warning Shot

By Michael Rosensaft

Recent enforcement actions signal the Office of Foreign Assets Control's (“OFAC”) increased scrutiny of professionals, including...

10/3/2025 2:30:13 PM

U.S. Bureau of Industry and Security Amends Export Administration Regulations to Add 50% "Affiliate" Rule for Entity and Military End-User Lists

By Jacques Semmelman

On Sept. 29, 2025, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") issued a new interim final rule (the "Rule")...

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United States Reverses Course on Iran: From General License X to Operation Economic Outcast in Two Months

The United States Removes Syria from the State Sponsors of Terrorism List

OFAC Issues General License X1, Withdrawing General License X's Grant of Broad Sanctions Relief on Iran's Oil and Petroleum Sector

OFAC Issues General License Authorizing Certain Transactions Incident and Necessary to the Sale, Delivery, or Offloading of Iran-Origin Crude and Petroleum Products

The $166 Billion Question: What Importers Need to Know About the Tariff Refund Process

OFAC Issues License Allowing Maduro’s Criminal Defense Counsel to Be Paid by Government of Venezuela, and then Revokes it

The Evolving Landscape of Presidential Tariffs After the Supreme Court’s Decision in Learning Resources v. Trump

OFAC Issues General License Authorizing Certain Transactions Incident and Necessary to the Sale, Delivery, or Offloading of Russian-Origin Crude and Petroleum Products

Serving as a Fiduciary for Sanctioned Clients? OFAC’s Recent Enforcement Action is a Warning Shot

U.S. Bureau of Industry and Security Amends Export Administration Regulations to Add 50% "Affiliate" Rule for Entity and Military End-User Lists

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