Economic / Financial / Trade Sanctions

(Preeminent Expertise)

Unparalleled Economic Sanctions Knowledge, Experience, and Strength

We offer practical advice and insight to keep our global business clients who deal in the international transfer of goods, services, and money flows from being tripped up by the treacherous minefield of laws and regulations governing economic sanctions and export controls. We also have our finger on the pulse of the latest developments in EU and other sanctions so that we are able to provide up-to-the-minute, precise analysis and advice, help our clients avoid violations, and advise them on what is not prohibited.

Collectively, our lawyers have more than 80 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.

We are a boutique law firm based in Washington, D.C., and we are one of the world’s leading firms in the area of economic sanctions. Our Firm is comprised of lawyers who have served in senior positions at the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the U.S. State Department.

We advise and represent clients with respect to all aspects of U.S. economic sanctions and the laws and regulations governing them. We have deep knowledge and experience, especially with respect to current policies underlying current Iran and Russia sanctions and how these sanctions apply to U.S. as well as non-U.S. persons.

Experience and Insight

Mr. Eren and Mr. Pinter

Mr. Eren and Mr. Pinter of The Eren Law 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, in 2000 and 2002, respectively. 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. Eren and Mr. Pinter advise and represent financial institutions, financial services companies, and other clients with respect to all aspects of OFAC-administered sanctions and U.S. anti-money laundering (AML) laws and regulations. They design OFAC and AML compliance programs and conduct risk assessments for clients. Additionally, Mr. Eren and Mr. Pinter represent clients in applications for OFAC licenses (such as for the unblocking of funds / accounts and authorization for (exceptions to) prohibited transactions), SDN list removal petitions, and other sanctions relief; in sanctions and anti-money laundering enforcement proceedings; and in sanctions litigation, among other matters.

Mr. Pinter was OFAC’s Chief of Licensing for 17 years during which time he was one of the chief arbiters of all major OFAC decisions. Mr. Eren’s portfolio at the U.S. Treasury mainly involved issues and matters related to Iran, the former Yugoslavia, and the evaluation and authorship of OFAC responses to license applications and requests for interpretive guidance.

Complemented by Mr. Comras, who was the Director of Economic Sanctions Policy during his tenure at the State Department, 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.

Collectively, our lawyers have more than 80 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.

Fact: No other law firm has as much sanctions experience as we do.

The Elements of Our Sanctions Practice

Specifically, we assist clients in:

U.S. Treasury OFAC-administered sanctions (executive orders, statutes, regulations)

  • Advice, opinions, interpretations, guidance
  • Primary and secondary sanctions
  • Prohibitions and requirements
  • Exemptions
  • Licenses and exceptions (requests for OFAC licensing and exceptions to prohibitions, e.g., for the unblocking of blocked property, including frozen assets / blocked property wire transfers)
    • Questions of jurisdiction
    • Designing and adoption of compliance policies and programs, and compliance training
    • OFAC compliance policies and programs
    • Due diligence, legal opinions, and clearance for transactions
    • Conflicts of sanctions laws (international)
    • Reporting
    • 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 and testing
  • Enforcement and penalty defense (civil and criminal), formal administrative proceedings
  • Negotiations / informal settlements
  • Litigation, arbitration and other dispute resolution
  • Voluntary disclosures
    • Petitions for removal from the SDN list, Blacklist (SDN or OFAC list) removal petitions
  • Protection of assets and preparation for post-sanctions situations
  • Claims, claims settlement, expropriation issues, satisfaction of judgments
  • Export controls
  • Service as expert witnesses in legal proceedings

U.S. 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

North Korea Sanctions

Ukraine / Russia Sanctions

Cuba Sanctions

Syria Sanctions

Counter Terrorism Sanctions

Counter Narcotics Sanctions

Sanctions Against Designated Russian Entities, Crimea

Sanctions Against Venezuela

U.S. Secondary Sanctions – Venezuela, Russia

Advice, opinions, guidance, representation on all aspects of primary and secondary sanctions against, e.g., designated Russian and other entities (SDNs), Syria, Cuba, North Korea, and Venezuela.

U.S. 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 US 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.

Among other U.S. laws, the scope of U.S. sanctions against Iran was expanded subsequent to CISADA by:

  • 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 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 U.S. Sanctions

  • Advice, opinions, guidance
  • Advice on conflicts of laws