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Clifford Chance

Clifford Chance

Briefings

DC Circuit Upholds OFAC's Broad Interpretation of Transshipment Prohibition on US-Origin Goods to Iran

2 June 2017

On May 26, 2017, the US Court of Appeals for the District of Columbia Circuit threw out a portion of a $4,073,000 civil penalty assessed by the Office of Foreign Assets Control ("OFAC") against a California-based sound system wholesaler for violations of the Iranian Transactions and Sanctions Regulations ("ITSR"). However, the Court upheld OFAC's broad interpretation of the ITSR that a violation occurs if an exporter has reason to know its exports to a third country are intended to be re-exported to Iran.          

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