Sanctions, Sanctions and More Sanctions: Iran, Venezuela and Russia

In November 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took a number of actions in connection with the re-imposition, or “snap-back,” of sanctions on Iran. As Nov. 4, 2018 marked the end of the 180-day wind-down period, all U.S. sanctions lifted or waived in connection with the Joint Comprehensive Plan of Action were re-imposed and in full effect as of that date. On Nov. 5, 2018 — a day that OFAC called “its largest ever single-day action targeting the Iranian regime”— OFAC sanctioned over 700 individuals, entities, aircraft and vessels, including the designation of over 70 Iran-linked financial institutions, to the Specially Designated Nationals and Blocked Persons List. In this article, Betty Santangelo, Gary Stein and former Schulte lawyers Jennifer Opheim, Seetha Ramachandran, Mari Dopp and Nicole Geoglis provide updates on the latest sanctions regarding Iran, Venezuela and Russia.