Economic / Financial / Trade Sanctions (Preeminent Expertise)
We offer practical advice and insight to keep our global business clients that deal in the international transfer of goods and services from being tripped up by the treacherous minefield of laws and regulations involving sanctions and export controls compliance. We also have our finger on the pulse of the latest developments in international sanctions so that we can provide up-to-the-minute advice, perform comprehensive due diligence, and help our clients avoid regulatory enforcement actions.
Collectively, our lawyers have more than 60 years of unrivaled full-time experience dealing with all aspects of international banking and financial issues implicating economic sanctions, export controls, and anti-money laundering laws. The elements of our sanctions practice:
US Treasury OFAC-administered sanctions (executive orders, statutes, regulations)
The Eren Law Firm is a leading economic sanctions boutique law firm based in Washington, DC and one of the world’s leading firms in the area of economic sanctions. The Firm is comprised of lawyers who have served at the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the U.S. State Department, and the U.S. Justice Department.
Mr. Eren and Mr. Pinter of the firm served in senior positions at OFAC of the U.S. Treasury Department, the agency that administers U.S. economic sanctions, for a combined 30 years before entering private practice respectively, in 2000 and 2002. Since this time, they have devoted and continue to devote most of their time in private practice to economic sanctions issues and matters, particularly those involving Iran, Russia and Venezuela. Mr. Pinter was OFAC’s Chief of Licensing for 17 years during which time he was one of the chief arbiters of OFAC decisions. Mr. Eren’s portfolio at Treasury mainly involved issues and matters involving Iran and the former Yugoslavia, and the evaluation and authorship of OFAC responses to license applications and requests for interpretive guidance.
Mr. Eren and Mr. Pinter advise and represent financial institutions, financial services companies, and other clients with respect to all aspects of OFAC-administered sanctions as well as U.S. anti-money laundering (AML) laws and regulations. They also design OFAC and AML compliance programs and conduct risk assessments for clients, and represent clients in, among other matters, applications for OFAC licenses (such as for the unblocking of funds and accounts, and authorization for prohibited transactions), SDN list removal petitions, other sanctions relief; in sanctions, and anti-money laundering enforcement proceedings; and in sanctions litigation.
Complemented by Mr. Comras, who during his tenure at the State Department was the Director of Economic Sanctions Policy, Mr. Eren and Mr. Pinter also provide clients with a unique insight and perspective on the policies underlying sanctions, and help clients to see big-picture sanctions issues.
We offer practical advice and insight to keep our global business clients that deal in the international transfer of goods and services from being tripped up by and help to comply with complex laws and regulations involving sanctions and export controls.
Collectively, our lawyers have more than 60 years of unrivaled full-time experience dealing with all aspects of international banking and financial issues implicating economic sanctions, export controls, and anti-money laundering laws.
No other firm has as much experience as we do.
We advise and represent clients in all aspects of U.S. economic sanctions, U.S. anti-money laundering laws, as well as U.S. export controls and other financial/trade regulatory matters.
The elements of our sanctions practice:
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- Advice, Opinions, Interpretations, Guidance
- Primary and Secondary Sanctions
- Prohibitions and Requirements
- Licenses and Exceptions
- Questions of Jurisdiction
- Compliance Policies and Programs, Compliance Training
- Due Diligence
- Conflicts of Sanctions Laws (international)
- Advice on Complex Issues Facing Banks and Financial Services Companies
- U.S. Banks, U.S. Branches of Foreign Banks, Foreign Banks, Broker-Dealers, Investment Banks, Insurance Companies
- Intersection/Interplay of Sanctions and Anti-Money Laundering Laws
- Advice, Representation, Advocacy
- License Applications and Other Sanctions Relief
- Trade and financial transactions/activities, blocked funds and contracts
- Requests for Interpretive Guidance
- Internal Investigations/Look-Backs
- Compliance Audits & Testing
- Enforcement and Penalty Defense (civil and criminal)
- Formal Administrative Proceedings, Negotiations/Informal Settlements
- Voluntary Disclosures
- Blacklist (SDN or OFAC List) Removal Petitions
- Protection of Assets and Preparation for Post-Sanctions Situations
- Claims, Claims Settlement, Expropriation Issues, Satisfaction of Judgments
US Helms-Burton Sanctions (Cuba)
The Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996 (the “Helms-Burton Act”) provides a cause of action under U.S. federal law pursuant to which U.S. nationals may sue any person who “traffics” in property that was expropriated from a U.S. national by the Cuban Government on or after January 1, 1959.
- Advice, Opinions, Guidance, Representation
- Advice on Conflicts of Laws
US Secondary Sanctions
- Advice, Opinions, Guidance, Representation on all aspects of primary and secondary sanctions against e.g., Iran, designated Russian and other entities (SDNs), Syria, Cuba, North Korea, and Venezuela.
US Secondary Sanctions - Iran
The U.S. sanctions against Iran are divided into two categories. The Secondary Sanctions apply to certain defined transactions with Iran by non-U.S. persons and where there is otherwise no U.S. nexus to relevant transactions. The Primary Sanctions against Iran apply to transactions by U.S. persons involving Iran or to transactions with a U.S. nexus. The Secondary Sanctions against Iran were lifted for a brief period but were reimposed upon the U.S. withdrawal from the JCPOA.
Chronology of U.S. Secondary and Statutory Sanctions- Iran
In 2010, the U.S. enacted the Comprehensive Iran Sanctions Accountability and Divestment Act (“CISADA”), which expanded the scope of the former Iran Sanctions Act.
The scope of U.S. sanctions against Iran were expanded subsequent to CISADA by, among other U.S. laws:
- the National Defense Authorization Act of 2012 (the “2012 NDAA”),
- the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”),
- Executive Order 13662, and
- the Iran Freedom and Counter-Proliferation Act of 2012 (“IFCA”).
Several Executive Orders and amendments to relevant regulations related to the foregoing were issued.
The U.S. has also taken a number of steps toward implementing aspects of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), a major piece of Iran sanctions legislation, which creates authority for the imposition of sanctions on additional non-U.S. persons (entities and individuals) that work with and support Iran’s defense, energy and military sectors.
UK, EU, Canadian and Other Countermeasures to US Sanctions
- Advice, Opinions, Guidance
- Advice on Conflicts of Laws