Akrivis wishes its clients and friends a very joyous and blessed Eid / Bayram holiday marking the end of the holy month of Ramadan.

Managing Partner Farhad Alavi was interviewed and quoted in a Bloomberg article titled Did Donald Trump’s Executives Violate the Cuban Embargo? The article covers repeated travel to Cuba by affiliates of the Trump Organization where potential hotel and golf course sites were scouted on the island state, and how this can be interpreted as a violation of the United States’ longstanding embargo. Despite a recent loosening of the Cuban sanctions, most business with Cuba remains off-limits for U.S. persons, and unfettered travel without specific authorization from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is still not permitted, rather, travel must be through one of a limited number of permissible transactions.

Akrivis Law Group, PLLC is pleased to release its latest Client Alert, titled United States implements significant relaxation of Cuba Sanctions, co-written by Managing Partner Farhad R.  Alavi and Senior Counsel Eric N. Ubias. This Client Alert concisely details some of the key changes to the U.S. sanctions regime in place against Cuba as implemented earlier this week.

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For more information contact Farhad R. Alavi at falavi@akrivislaw.com or +1.202.686.4859 or Eric N. Ubias at eubias@akrivislaw.com or +1.202.730.1271.

The U.S. Court of Appeals for the District of Columbia Circuit ruled today in favor of our client Epsilon Electronics, Inc., in a case against the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the primary U.S. government body administrating trade restrictions against sanctioned countries like Iran and Cuba. This case is already the subject of exceptional interest and significance for the trade compliance community. The ruling is particularly timely in the aftermath of the agreement over Iran’s nuclear program resulting in the 2015 Joint Comprehensive Plan of Action (JCPOA), which led to partial but not complete sanctions relief for Iran.

November 6, 2018.  Akrivis Law Group, PLLC is pleased to issue its latest Client Alert, titled U.S. Completes Reintroduction of Post-JCPOA Iran Sanctions.  The United States completed its phase-in of sanctions against Iran following the decision by President Donald Trump to withdraw from the Joint Comprehensive Plan of Action (JCPOA, commonly referred to as the Iran nuclear deal), which has been entered into by Iran and the “P5+1” states (the United States, United Kingdom, France, Russia, China, and Germany) in 2015 and implemented in 2016.  These are mainly sanctions that had been lifted and/or relaxed as a result of that agreement.

On October 18, 2017, Akrivis Law Group, PLLC with the help of its friends at AmCham Abu Dhabi, held a compliance briefing at the Ritz-Carlton Dubai International Financial Center (DIFC).  Managing Partner Farhad Alavi presented on the latest developments in the U.S. sanctions framework and answered questions.

Akrivis Law Group, PLLC co-hosted a trade compliance seminar in Copenhagen, Denmark on April 8, 2019 with Gorrissen Federspiel, one of Scandinavia’s leading law firms. This workshop, held at the Danish firm’s Copenhagen headquarters, was led jointly by Farhad Alavi, Partner, and Camilla Collett, Partner, and Ida Krogh-Otzen, Assistant Attorney, Gorrissen Federspiel.  The discussion focused on U.S. and E.U. sanctions, export controls, and related issues, both from a compliance and enforcement angle.

July 24, 2019. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) yesterday issued an advisory on matters pertaining to Iran’s civil aviation sector. Our Client Alert can be read and downloaded here.

We are proud to announce that we secured the removal of Akrivis Law Group, PLLC client Technology Links Pvt. Ltd. from the U.S. Department of Commerce’s Bureau of Industry & Security (BIS) Entity List.

Akrivis Law Group, PLLC and AZHA Avocats of Switzerland co-hosted a sanctions compliance seminar in Geneva at the Hotel President Wilson on Thursday, January 16, 2020. The event was headlined by Akrivis partner Farhad Alavi and AZHA partner Mercedeh Azeredo da Silveira. Other speakers from the United Kingdom and France also presented. The event was attended by roughly 60 people from throughout Europe.

On July 1, the U.S. Departments of State, the Treasury, Commerce, and Homeland Security issued a detailed advisory (the “Advisory”). This is in response to the various types of regulatory exposure companies could face when dealing with suppliers and vendors in China’s northwestern Xinjiang region, given substantial allegations of forced labor and other human rights abuses there.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced on October 20 that it was imposing a $4.1 million penalty against Omaha, Nebraska-based Berkshire Hathaway Inc., its subsidiary  MC International Metalworking Companies B.V. (“IMC”) and IMC’s wholly owned Turkish subsidiary, Iscar Kesici Takim Ticareti ve Imalati Limited Sirket (“Iscar Turkey”) for illicit transactions by Iscar Turkey with Iran.  Iscar Turkey is in the business of manufacturing machinery, specifically cutting tools and inserts.  The violations took place between 2012 and 2016, with Iscar Turkey entering into 144 transactions with Iran over that period. While announcements of OFAC penalties for sanctions violations are not rare, this one has a few notable points.

WorldECR (Export Control Review), a premier trade publication based in London, last month published an article co-authored by Akrivis Law Group, PLLC Partner Farhad Alavi and Daisuke Takahashi of Shinwa Sohgoh Law Offices in Japan on removal from the U.S. Department of Commerce’s Bureau of Industry & Security (BIS) Entity List and Japan’s Ministry of Economy, Trade, and Investment (METI) End-User List.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued two penalties against non-U.S. financial institutions this past week. The agency’s December 28, 2020 settlement with Saudi Arabia-based National Commercial Bank (NCB) and its January 4, 2021 settlement with France-based Union de Banques Arabes et Françaises (UBAF) arguably demonstrate a more detailed evaluation by OFAC of compliance procedures and activities of foreign financial institutions processing U.S. dollar (USD) payments. Additionally, they may potentially signal more enforcement actions against foreign financial institutions going forward.

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Akrivis Law Group Partner Farhad Alavi will be on a May 25 webinar panel sponsored by the American Chamber of Commerce Abu Dhabi (AmCham Abu Dhabi) including former US Ambassador to the UAE Michael Corbin, as well as other distinguished guests. Titled “Trade Expectations in the Biden Era: Policy, Diplomacy and Export Controls,” the four member panel will discuss important trade issues in the new administration, with emphasis on how they impact the UAE, US-UAE trade, and the broader region. The panel will be moderated by Charles Laubach, secretary of AmCham Abu Dhabi and a partner at Afridi & Angell in Dubai.

The U.S. Department of Commerce’s Bureau of Industry & Security yesterday added 34 entities (43 entries in total) to its Entity List, placing those parties under a near blanket ban on U.S. origin goods and technologies.

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Our Client Alert, which summarizes the decision and provides insights into its significance, can be downloaded by clicking on the image below or clicking here.

As a potential invasion of Ukraine by Russia appears increasingly likely, many are speculating about the potential for U.S. sanctions. Our Client Alert, written by Akrivis Law Group partners Farhad Alavi (Washington) and Sam Amir Toossi (New York), provides some key insights as to what these trade restrictions may look like and how U.S. and non-U.S. companies can prepare accordingly. Download the PDF here.

Akrivis Partners Farhad Alavi (Washington) and Sam Amir Toossi (New York) led a Continuing Legal Education (CLE) webinar hosted by the Practising Law Institute (PLI) on Russia sanctions issue, an ever important area in the international trade compliance field. The one-hour webinar, titled Overview of Russian Economic Sanctions – Past and Present, focuses on the ramp up of Russian sanctions, key new changes, and how companies can focus and sharpen their compliance approaches and wind-down strategies.

The U.S. Departments of the Treasury and State and the Federal Bureau of Investigations (FBI) yesterday issued a joint advisory (the “Advisory”) on North Korean information technology (IT) workers informing the business community of the sanctions risks associated with recruiting and hiring individuals such as freelance developers and alerting the public to deceptive practices by such persons. The interagency guidance explains how the North Korean IT workers operate, identifies indicators that raise red flags, and suggests mitigation measures, such as due diligence to help employers from unwittingly hiring them.

Sam Amir Toossi, Partner, New York

Following Russia’s invasion of Ukraine, the United States quickly imposed sweeping sanctions on Russian entities and individuals, which the Biden Administration immediately began to take steps to aggressively enforce.  The Department of Justice (DOJ) announced the formation of the KleptoCapture Task Force, an interagency law enforcement effort to enforce the sanctions and restrictions designed to punish Russia’s actions in Ukraine.

The U.S. Departments of State, Treasury, Commerce, and Labor on May 23 issued an advisory for US businesses operating in Sudan, highlighting the growing risk to US businesses and individuals associated with conducting business with Sudanese State-Owned Enterprises (SOE), which are entirely controlled by Sudan’s military following its seizure of power on October 25, 2021.

On October 21, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) added 26 companies and individuals to the Entity List for engaging in activities contrary to U.S. national security and foreign policy.  The entities added were from the following jurisdictions: China (6), Egypt (1), Pakistan (16), and the United Arab Emirates (UAE) (3). These additions were made under various rationale, including alleged violations of export controls, evasions of U.S. sanctions on Russia and Iran, and involvement in weapons programs of concern.  The move follows a recent trend of significant increases in Entity List additions.  Nine of the Pakistani entities named to the Entity List this week were added for being associated with a previously identified company already on the Entity List, while the remaining seven were added for contributions to Pakistan’s ballistic missile program. The three UAE entities as well as the one Egyptian entity were added for acquiring U.S.-origin parts to evade U.S. Sanctions imposed on Russia.  The six Chinese entities were added for acquiring U.S.-origin items in support of their military modernization, dilatory and evasive conduct during end-use checks, and procurement of U.S.-origin items for Iran’s weapons of mass destruction program.

In its latest move to counter the national security threat posed by Russia sanctions invaders, the Biden Administration targeted over 300 companies and individuals around the world on Wednesday, October 30, placing them under either sanctions or export controls lists.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on May 23 issued a general license (GL-25) effectively lifting most prohibitions on U.S. persons on that country. This move follows President Trump’s meeting with Syrian President Ahmad Al-Sharaa earlier in the month, which in turn follows the fall of the Assad government in December 2024.

Akrivis Law Group PLLC is pleased to announce that the firm and our Florida-based partner Walter Norkin have been ranked in Chambers in the field of Litigation: White Collar Crime & Government Investigations.

Farhad Alavi (Washington Partner), Sam Amir Toossi (New York Partner), and Valentin Povarchuk (Washington Counsel) will be attending the 2025 International Bar Association (IBA) Annual Conference in Toronto this year, which will be held between November 2-7.

The U.S. Department of Commerce’s Bureau of Industry & Security (BIS) on September 29, 2025 took a significant yet anticipated step by adopting an Interim Final Rule, referred to as the Affiliates Rule, extending the restrictions imposed on entities listed on the Entity List (“EL”) to unlisted entities that are 50% or more owned by one or more of the listed entities.  Presently, naming to the Entity List, the BIS’s strictest listing of non-U.S. parties, was limited to the named entity and none of its legally distinct affiliates or subsidiaries.  This rule drastically changes that by capturing a wider range of related entities whose names would not necessarily be on the list.  This action will have a momentous impact on many companies in China and elsewhere, significantly increasing compliance burdens, particularly on companies doing business in or with sensitive regions.