Latest in Sanctions


The F-35 Dispute and Tensions in the U.S.-Turkey Relationship

The United States has taken several escalatory steps in recent months to suspend delivery of F-35 fighter jets to Turkey, currently scheduled for November 2019. On Feb. 15, the Consolidated Appropriations Act of 2019 (§ 7046) restricted funding for the delivery of F-35s to Turkey absent a report on Turkey’s pending purchase of Russian S-400 missiles, due by November 2019.


The U.S. Names the Iranian Revolutionary Guard a Terrorist Organization and Sanctions the International Criminal Court

On April 8, the Trump administration designated the Islamic Revolutionary Guard Corps (IRGC) as a foreign terrorist organization (FTO) under Section 219 of the Immigration and Nationality Act. A few days earlier, the administration had made good on its threat to impose sanctions on officials of the International Criminal Court (ICC) involved in the examination of U.S. actions in Afghanistan and Israeli actions in other contexts. As part of this effort, it revoked the U.S. visa of Fatou Bensouda, the ICC’s chief prosecutor.


How Securities Law Can Help the U.S. Counter INSTEX

On Jan. 31, the governments of France, Germany and the United Kingdom formally announced the establishment of the Instrument in Support of Trade Exchanges (INSTEX), a Special Purpose Vehicle dedicated to facilitating trade between European economic actors and Iran. The creation of INSTEX by the three countries—known as the E3—followed months of negotiations in the wake of the United States’s 2018 exit from the Iran nuclear deal.


The Deter Act: Congress’s Latest Effort to Discourage Election Interference

New movement may be afoot on a sanctions bill designed to deter Russian election interference. The bill, the Defending Elections from Threats by Establishing Redlines Act of 2018 (Deter Act), was introduced earlier this year by Sens. Marco Rubio (R.-Fla.) and Chris Van Hollen (D.-Md.).


The Newest Round of Russian Sanctions: Much Ado About Very Little

On March 15, the Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned five Russian entities and nineteen individuals for “malign” cyber activity, “including their attempted interference in U.S. elections, destructive cyber-attacks, and intrusions targeting critical infrastructure.” This most recent round of sanctions is interesting for at least two reasons.


Is the Trump Administration Breaking the Law By Failing to Issue New Russia Sanctions?

Author’s Note: After drafting the post below, I belatedly checked Lawfare’s recent posts to ensure I’m not preempted. And there I found this terrific post by my colleague Megan Reiss, covering a great deal of the same ground on the Section 231 and 241 issues (and doing a much better job of contextualizing them).


Separation-of-Powers Objections to the Iran Nuclear Agreement

In a recently published article, “Taking Steel Seizure Seriously: The Iran Nuclear Agreement and the Separation of Powers,” 86 Fordham L. Rev. 1199 (2017), Steven Menashi and I question the constitutional validity of President Barack Obama's decision, as part of the 2015 Joint Comprehensive Plan of Action agreement with Iran and five other countries, to repeal, in effect, 17 different Iran-related nuclear sanctions provisions for the agreement’s 15-year term.


Is Iran Trying to Inflate Yemen’s Currency as a Tool of Warfare?

On Nov. 20, the Treasury Department’s Office of Foreign Assets Control, which enforces sanctions, identified and designated individuals and entities connected to an operation by the Quds force, the special forces division of Iran’s Revolutionary Guard Corps (IRGC) to print counterfeit Yemeni money worth hundreds of millions of U.S. dollars using European equipment.

Subscribe to Lawfare