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OFAC Responds to COVID-19 in Iran

On March 6, 2020 and in response to an outbreak of coronavirus in Iran, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance pertaining to the manner in which humanitarian goods and assistance may be provided to the people of Iran consistent with U.S. sanctions against Iran. This two-part post … Continue Reading

Iran’s “Trojan Horse” Bank

The Kingdom of Bahrain recently filed its statement of defence in an ongoing UNCITRAL arbitration in the Permanent Court of Arbitration (“PCA”) in The Hague against Iranian financial institutions Bank Melli and Bank Saderat. The statement of defence cites a Bahraini government audit evidencing a multibillion-dollar corruption scheme perpetrated by Bank Melli and Bank Saderat … Continue Reading

Oil and Gas Giant Total S.A. Pays Fourth Highest Penalty In FCPA Enforcement History

On May 29, 2013, Total S.A. (“Total”), the French oil and gas conglomerate, entered into a three-year deferred prosecution agreement (DPA) with the DOJ and a settlement agreement with the SEC to resolve past violations of the FCPA’s anti-bribery, books and records and internal controls provisions.  As part of the agreements, Total will pay $245.2 … Continue Reading
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