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Iran OFAC Sanctions · ITSR

Iran OFAC Sanctions
Lawyer in Dubai

Expert ITSR compliance, enforcement defense, and Iran-related OFAC license counsel for UAE and international businesses. Dr. Shaun Gregory Morgan — senior partner available from day one.

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Dr. Shaun Gregory Morgan
Iran Sanctions Specialist · Dubai
LLM — Northwestern University School of Law
MSc Economics — LSE (2000)
NY State Bar No. 1210887
OFAC Matters Handled200+
Client Penalties$0
Licenses Approved15+
Years Experience20+
Call Dubai Office
200+
OFAC Matters Handled
$0
In Client Penalties
15+
Iran Licenses Approved
20+
Years Experience
Iran Sanctions Overview

Iran OFAC Sanctions & the UAE Business Risk

The United States maintains one of the world's most comprehensive sanctions regimes against Iran. Administered primarily through the Iran Transactions and Sanctions Regulations (ITSR), 31 CFR Part 560, these sanctions impose a near-total embargo on trade, financial services, and commercial dealings with Iran, the Government of Iran, and Iranian persons. For UAE-based businesses — which operate at the geographic and commercial intersection of Iran's regional economic sphere — Iran OFAC sanctions represent the single most significant US regulatory risk.

The UAE's position as a major re-export and transit hub, combined with the significant Iranian diaspora community and centuries-old Iran-UAE trading relationships, means that Iranian sanctions exposure is pervasive across Dubai's commercial landscape. UAE banks, trading companies, logistics firms, real estate developers, and professional services providers regularly encounter Iran nexus issues — often unknowingly. Under OFAC's strict liability standard for most ITSR violations, ignorance is not a defense: companies can face civil monetary penalties of up to $1.4 million per violation regardless of whether the violation was intentional.

Dr. Shaun Gregory Morgan brings over 20 years of US sanctions law experience — including extensive Iran OFAC matters — to clients operating from his Emirates Towers, Dubai office. Holding an LLM from Northwestern University School of Law and an MSc in Economics from the London School of Economics (LSE, 2000), with active New York State Bar membership (No. 1210887), Dr. Morgan is uniquely qualified to advise UAE businesses on the full spectrum of Iran sanctions risk — from compliance program design to enforcement defense and OFAC license applications.

How We Help

Iran Sanctions Legal Services

Comprehensive Iran OFAC sanctions counsel — from proactive compliance design to aggressive enforcement defense.

Iran Sanctions Compliance Review

We conduct privileged, comprehensive reviews of your business operations to identify Iran-related OFAC exposure — mapping customer relationships, supply chains, correspondent banking relationships, and transaction flows against the ITSR and SDN list to produce a prioritized risk remediation roadmap.

Enforcement Defense — Iran Violations

If you receive OFAC correspondence relating to apparent Iran sanctions violations, immediate engagement of experienced Iran sanctions counsel is critical. Dr. Morgan leads enforcement defense — managing all OFAC communication, preparing responses, negotiating settlements, and advocating for the most favorable outcome possible.

Iran OFAC License Applications

Certain Iran-related transactions — including humanitarian activities, journalistic operations, academic exchanges, and personal remittances — may be eligible for OFAC-specific licenses or covered by general licenses. We identify applicable authorizations and prepare compelling license applications supported by thorough legal and factual records.

Voluntary Self-Disclosure (VSD)

For companies that have discovered apparent Iran sanctions violations, a strategically prepared voluntary self-disclosure can dramatically reduce OFAC civil penalties — in many cases to zero. We conduct the internal investigation, scope the disclosure, prepare the VSD submission, and manage OFAC's follow-up investigation to maximize mitigation credit.

Iran Nexus Due Diligence

For M&A transactions, new counterparty onboarding, or unusual transaction patterns, we conduct bespoke Iran nexus due diligence — combining SDN screening, corporate ownership analysis, geographic risk assessment, and transactional pattern review to identify and quantify Iran-related OFAC exposure before it becomes a problem.

Iran Sanctions Training & Awareness

Frontline staff awareness is the first line of Iran sanctions defense. We deliver tailored Iran sanctions training programs for compliance teams, relationship managers, and senior management — covering red flag identification, customer due diligence protocols, escalation procedures, and real-world UAE case studies.

Regulatory Framework

Key Provisions of the Iran Sanctions Regime

The Iran sanctions regime is one of the most complex in the world, comprising multiple executive orders, federal regulations, and statutory frameworks. The key provisions most relevant to UAE-based businesses are outlined below.

Provision / ProgramLegal AuthorityWhat It ProhibitsUAE Risk Level
Iran Transactions & Sanctions Regs (ITSR)31 CFR Part 560Virtually all trade, financial, and commercial dealings with Iran⬛ Critical
Iranian Financial Sanctions Regs (IFSR)31 CFR Part 561Transactions with Iranian financial institutions; correspondent accounts⬛ Critical
Iranian Human Rights AbusesEO 13553 / EO 13628Dealings with designated Iranian government officials & security forces▪ Elevated
Secondary Sanctions (Non-US Persons)IFCA / CAATSA provisionsSignificant transactions with Iranian energy, shipping, shipbuilding sectors⬛ Critical
Iranian SDN DesignationsIEEPA / TWEAAll transactions with 1,000+ designated Iranian individuals and entities⬛ Critical
General License Exceptions31 CFR 560.500–560.580Permits certain humanitarian, journalistic, academic, personal transactions▪ Review Required

The Iran sanctions landscape changes frequently with new executive orders and SDN designations. Contact Dr. Morgan for the most current regulatory guidance. View our full OFAC compliance services →

Enforcement Defense

How We Handle Iran Sanctions Enforcement

When Iran sanctions exposure is identified, acting immediately and strategically is essential. Here is how Dr. Morgan's team responds.

1

Immediate Privileged Review

We conduct an immediate, privileged internal investigation to scope the potential violation — identifying affected transactions, counterparties, and regulatory exposure — so you understand the full picture before engaging with OFAC.

2

Strategic Decision: VSD vs. Wait

We advise on whether voluntary self-disclosure is in your best interest — analyzing OFAC discovery risk, penalty exposure, and mitigation credit to make a data-driven recommendation on the optimal disclosure strategy.

3

OFAC Engagement & Negotiation

We manage all communication with OFAC — responding to Requests for Information, presenting mitigating factors, advocating for no-action or no-penalty outcomes, and negotiating settlement terms that minimize financial exposure.

4

Remediation & Future Protection

Once the enforcement matter is resolved, we design and implement a comprehensive Iran sanctions compliance program to prevent future violations — including enhanced screening, training, internal controls, and a documented compliance commitment.

Common Questions

Iran Sanctions FAQ for UAE Businesses

Yes — and this is one of the most common misconceptions among UAE businesses. OFAC's secondary sanctions provisions allow it to penalize non-US companies for significant transactions involving Iran. Under CAATSA and various Iran sanctions statutes, OFAC can cut off non-US banks and companies from the US financial system if they engage in prohibited Iran-related transactions. For UAE businesses with US dollar clearing, US investors, or US business relationships, this exposure is extremely significant.

The ITSR contains a number of general license exceptions that permit certain categories of otherwise-prohibited Iran-related transactions without a specific license. These include: personal remittances, certain humanitarian goods, journalistic activities, academic and educational exchanges, and certain legal services. However, each general license has specific conditions and limitations that must be carefully reviewed before relying on them. A specific license from OFAC is required for any transaction not covered by a general license.

If your bank rejects or freezes a transaction citing Iran sanctions concerns, you should immediately contact an experienced Iran sanctions lawyer before taking any further action. Do not attempt to restructure the transaction or find an alternative routing without legal advice — this could constitute an aggravated violation. Dr. Morgan can rapidly assess the situation, advise on the regulatory risk, and engage with your bank and (if necessary) with OFAC to resolve the matter in the most favorable way possible.

Identifying Iran nexus in counterparties requires more than simply checking the SDN list — it also involves analyzing beneficial ownership structures, geographic risk indicators, correspondent banking relationships, transaction patterns, and product/service type. Iranian sanctions evasion is sophisticated, often involving multiple layers of front companies and third-country intermediaries. Dr. Morgan's team conducts comprehensive Iran nexus due diligence that goes far beyond standard compliance screening to identify hidden exposure.

OFAC does issue specific licenses for certain Iran-related transactions that serve important policy goals — including humanitarian activities, certain legacy contracts, and specific commercial transactions that OFAC determines are consistent with US foreign policy. Obtaining a specific license requires a detailed application demonstrating legal eligibility and policy justification. Dr. Morgan has obtained more than 15 OFAC-specific licenses across multiple sanctions programs, including Iran, and has deep knowledge of the criteria and arguments most likely to succeed.

Iran Sanctions Counsel · Dubai

Speak with a Leading Iran
Sanctions Lawyer in Dubai

Iran sanctions exposure can threaten your access to the US financial system and expose your business to penalties up to $1.4 million per violation. Don't wait. Dr. Shaun Gregory Morgan provides urgent, senior-partner Iran sanctions counsel from Emirates Towers, Dubai — 24/7 for critical matters.

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Emirates Towers, Level 42, Sheikh Zayed Road, Dubai, UAE
Carnegie Hall Tower, Level 27, 152 West 57th Street, New York, NY 10021
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