January 16th Marked Changes in U.S. Sanctions on Iran

Matthew J. Thomas, Jonathan K. Waldron, and Dana S. Merkel

Action Item: January 16, 2016, marked Implementation Day under the Joint Comprehensive Plan of Action (“JCPOA”), an agreement between Iran and the EU3+3 nations (the United Kingdom, France, Germany, Russia, China, and the United States) to ease international trade sanctions in exchange for constraints on Iran’s nuclear capabilities. As of January 16, the United States lifted a number of nuclear-related sanctions on Iran, particularly the so-called “secondary sanctions” related to non-U.S. persons. With limited exceptions, U.S. persons and companies continue to be broadly prohibited from engaging in transactions with Iran, but a limited exception has been implemented to permit foreign subsidiaries of U.S. entities to do business with Iran in some circumstances. Continue reading “January 16th Marked Changes in U.S. Sanctions on Iran”

Congress “Almost” Takes Action on the “Coast Guard Authorization Act of 2015”

Mainbrace | January 2016 (No. 1)

Jonathan K. Waldron and Joan M. Bondareff

In the waning hours of the first session of the 114th Congress, the Senate passed H.R. 4188, an “Act to authorize appropriations for the Coast Guard for fiscal years 2016 and 2017, and for other purposes,” but the House of Representatives had already recessed for the year so final passage has been stalled until 2016. We anticipate that the House will take up the bill within the first two months of 2016, pass it without further amendment, and send it off to the President for his signature. Therefore, we have summarized the Senate enrolled bill, below, with our fondest hopes that the House decides not to tinker with the bill any further… Continue reading “Congress “Almost” Takes Action on the “Coast Guard Authorization Act of 2015””

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