Mr. Cutler is the Senior Analyst at Horizon Client Access. Formerly he was the Policy Adviser at Ferrari & Associates P.C. where he counseled clients on the intersection between U.S. foreign policy and U.S. sanctions law. He is also the Editor in Chief of Sanction Law, a blog and online resource dedicated to U.S. economic sanctions.
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With the flurry of news surrounding and leading up to Lt. General Michael Flynn’s resignation as national security advisor, our collective focus has once again returned to the bizarre connections between the Trump transition team (now administration) and the Kremlin.
For sanctions-watchers, the familiar rhythm of responding to new general licenses issued by Treasury’s Office of Foreign Assets Control (OFAC) is typically uneventful. You receive an email from OFAC announcing the measure, you momentarily consider its impact, and then return to whatever you were doing before. The era of Donald Trump, however, has injected “observe Twitter have a complete meltdown” into the cycle. I admire the passion and welcome new devotees to the exciting world of sanctions, but for today, a deep breath is required.
While the Joint Comprehensive Plan of Action (“JCPOA”) appears to have overcome the last major congressional hurdle to implementation, the latest quixotic attempt to tie sanctions relief to Iran’s payment of damages to plaintiffs in terrorism-related lawsuits notwithstanding, Congress has made it abundantly clear that legislative efforts vis-à-vis Iran will continue.