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On September 21, 2015, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) introduced a second round of amendments (the “September Amendments”) to the Cuban Assets Control Regulations (“CACR”) and the Export Administration Regulations (“EAR”) in a continuing…

On 14 July 2015, Iran and the EU/E3+3 (China, France, Germany, the Russian Federation, the United Kingdom, the United States, and the European Union) announced that they had agreed on a Joint Comprehensive Plan of Action (“JCPOA” or “Agreement”) regarding the lifting of sanctions currently imposed against Iran. If fully…