U.S. Escalates Iran Sanctions While Further Easing Syria Restrictions

                 The Treasury Department’s Office of Foreign Assets Control (“OFAC”) has expanded the sectors of the Iranian economy subject to secondary sanctions, suspended several longstanding general licenses and other authorizations, imposed additional sanctions targeting Iran’s civil aviation sector, and adopted a presumption of denial for Iran-related specific license applications. At the same time, the United States has continued to ease restrictions on Syria, including rescinding its designation as a State Sponsor of Terrorism, but the full implementation of that change is yet to come.