Iran Sanctions Lawyer

What Iran Sanctions Can an Attorney Help With?

Iran is subject to one of the most expansive US sanctions programs in existence. OFAC enforces dozens of Iran-related designations and regulatory prohibitions that affect individuals, companies, and financial institutions across the globe. Our Iran sanctions attorneys provide end-to-end legal support for:

• Blocked fund releases — applying for OFAC specific licenses to unfreeze Iranian-linked assets
• ITSR compliance reviews — auditing transactions and business relationships for Iran sanctions exposure
• SDN list removal — filing administrative delisting petitions for individuals and entities wrongly or outdatedly designated
• Iran license applications — preparing and submitting specific license requests to OFAC for authorized transactions
• Enforcement defense — representing clients under OFAC investigation for Iran sanctions violations
• Secondary sanctions risk assessment — advising non-US businesses on indirect Iran exposure and mitigation strategies
• Transaction structuring — designing compliant deal structures involving Iran-adjacent counterparties
• Due diligence programs — building internal sanctions screening and compliance frameworks

OFAC Iran Sanctions Programs

The Iranian Transactions and Sanctions Regulations (ITSR), codified at 31 CFR Part 560, form the legal backbone of US Iran sanctions policy. Administered by the US Treasury’s Office of Foreign Assets Control (OFAC), the ITSR broadly prohibits all US persons from engaging in trade, financial transactions, or services involving Iran or the Government of Iran — with very limited exceptions.

Key ITSR restrictions include:

• A near-total embargo on the import and export of goods, services, and technology to or from Iran
• Prohibition on all financial transactions involving Iranian banks, government entities, and state-controlled businesses
• Restrictions on correspondent banking relationships with Iranian financial institutions
• Blocking of property and interests in property of designated Iranian parties on the SDN list
• Secondary sanctions targeting significant transactions in Iran’s oil, petrochemical, shipping, and defense sectors — regardless of the transacting party’s nationality

In 2025, under a renewed “maximum pressure” policy, OFAC added 155 Iranian persons and over 180 oil-shipping vessels to the SDN list. Enforcement actions also targeted Chinese, UAE, and European companies facilitating Iranian oil exports — demonstrating that Iran sanctions reach well beyond US borders. Non-compliance carries civil penalties of up to $1.3 million per violation.

Iran Sanctions License Applications

OFAC issues both general licenses and specific licenses that can authorize otherwise-prohibited Iran-related transactions. Understanding which license applies — and how to obtain it — often determines whether a client can access frozen funds, complete a legitimate transaction, or resolve a compliance crisis.

General licenses automatically permit certain categories of transactions without individual OFAC approval, including:

• Informational materials — import/export of books, films, music, and publications
• Journalistic activities — transactions necessary for reporters operating in or covering Iran
• Personal remittances — limited transfers to family members in Iran
• Academic exchanges — participation in educational programs with Iranian institutions
• Emergency humanitarian transactions — certain medical and food-related transfers

Specific licenses are required when a transaction falls outside any general license. OFAC reviews applications on a case-by-case basis. Common situations requiring a specific license include releasing blocked accounts, completing partially-executed contracts with Iranian parties, or resolving inheritance and estate matters involving Iranian assets.

Our OFAC Iran lawyers prepare specific license applications that clearly articulate the legal basis for relief, address OFAC’s likely concerns proactively, and present supporting documentation in the format OFAC expects. A well-structured application significantly shortens review timelines and reduces the risk of denial.

Secondary Sanctions for Non-US Businesses

One of the most misunderstood aspects of Iran sanctions is their extraterritorial reach. Secondary sanctions allow OFAC to penalize non-US companies and individuals for conducting significant transactions with Iran — even if those transactions have no connection to the United States, no dollar clearing, and no US participants.

For EU, UK, and other international businesses, this creates a dual compliance obligation: they must comply not only with their own domestic Iran restrictions (EU Regulation 267/2012, UK’s Iran (Sanctions) (Nuclear) Regulations), but also avoid triggering US secondary sanctions that could result in:

• Designation on the US SDN list — effectively cutting off access to the US financial system
• Loss of US correspondent banking relationships
• Prohibition on US persons conducting business with the sanctioned entity
• Reputational damage and loss of US-market business partners

In 2025-2026, OFAC demonstrated willingness to designate European, Asian, and Middle Eastern companies for facilitating Iranian petroleum exports and evading the SDN list through front companies. Our Iranian sanctions compliance attorneys help non-US businesses map their exposure, implement screening controls, and obtain legal opinions that document good-faith compliance efforts — a critical factor if OFAC ever opens an inquiry.

Why Hire Our Iran Sanctions Lawyers?

Iran sanctions cases require specialized knowledge that general legal counsel rarely possesses. OFAC procedures, ITSR regulatory nuances, SDN delisting strategy, and specific license drafting are highly technical areas where experience directly correlates with outcomes. Our team offers:

• Dedicated OFAC practice — we focus exclusively on sanctions law, not as a side practice
• Proven track record — successful specific license approvals, SDN removals, and enforcement resolutions
• Global client base — we represent US persons, EU companies, financial institutions, and international individuals
• Fast response — sanctions emergencies require immediate action; we prioritize time-sensitive matters
• Transparent fees — clear retainer structures with no billing surprises
• Free initial consultation — assess your exposure before committing to representation

Whether you are facing a blocked wire transfer, an unexpected OFAC inquiry, a secondary sanctions risk in your supply chain, or an SDN designation that is preventing normal business operations — our Iran sanctions lawyers are ready to help. Contact us today for a confidential, no-obligation consultation.