Despite a host of unanswered questions, national security concerns and political barriers, Boeing announced on June 22, 2016 that it has signed a Memorandum of Agreement (MOA) with state-owned Iran Air. If finalized, the agreement would mean that Boeing could sell up to 100 commercial aircraft to Iran, at a cost of roughly $25 billion.

Boeing reportedly obtained a license from the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) to execute the MOA and engage in the negotiations that led to its signing. (OFAC is the U.S. government agency that administers most U.S. economic sanctions on Iran.) That authorization was made possible due to a new licensing policy relating to commercial passenger aircraft that OFAC issued in January 2016, following the July 2015 Joint Comprehensive Plan of Action (JCPOA) between the United States and its allies and Iran. The JCPOA significantly scaled back sanctions against Iran.

Continue Reading Iran Update: The Significance of the Boeing Deal

Since our update in April of this year, the U.S. government has continued to aggressively modify and enforce its various sanctions programs. And this trend shows no signs of slowing in the months to come.

As in the first quarter of 2015, the last three months were marked by a combination of broad policy changes, individual designations and removals, and various enforcement actions. While recent developments did not include the overhaul of any sanctions program akin to the Cuba amendments in January, they did set the stage for significant changes in the future.

Here, we consider notable U.S. sanctions developments in the past quarter, and offer our thoughts on what is to come.

Continue Reading Keeping Up the Pace: U.S. Sanctions Post a Busy Second Quarter