General Note on the Continued Relevance of the IACR, its relationship to the ITSR, and the Occasional Usefulness of OFAC Amicus Briefs in IACR-Related Litigation (System Ed. Note)

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TURBOFAC Commentary (1534 words)

General Note on the Continued Relevance of the IACR, its relationship to the ITSR, and the Occasional Usefulness of OFAC Amicus Briefs in IACR-Related Litigation (System Ed. Note)

The IACR is unique among active sanctions programs insofar as it is, as of 5/2019, close to irrelevant for ordinary sanctions compliance purposes, but is at the same time the sanctions program whose provisions are most frequently litigated. The litigation is almost entirely comprised of cases involving attempts by victims of terrorism to attach Iranian government assets through the FSIA, TRIA, or both. These attempts usually, but not always, fail. See generally "Notable OFAC Declarations/Statements of Interests" pertaining to the IACR, and comments thereto.

Often, the U.S. government will either intervene in a...