Criminal Sanctions Under the International Emergency Economic Powers Act

(104 Ratings)

Produced on: June 10, 2016

Course Format On Demand Audio

Taught by


Course Description

Time 62 minutes
Difficulty Intermediate

Sanctions have increasingly come to the forefront in recent years as a critical tool of U.S. foreign policy, translating into stricter enforcement by the U.S. Departments of Justice, the Treasury, and Commerce. Criminal and civil investigations into alleged sanctions and export controls violations can be massive, disrupting, costly, and lead to substantial penalties, as can be seen in the multi-million (and billion) dollar penalties imposed on various banks in the past few years. Even cases where no penalties are imposed can exact tremendous costs on companies, including legal fees, but arguably more importantly, disruption of business activities and reputational damage, among others. This seminar covers the key components of criminal investigations – how to manage the situation from the onslaught and zealously and effectively represent your client.

Learning Objectives:

  1. Work with the Office of the U.S. Attorney (OUSA) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS)
  2. Understand the complex regulatory context and be responsive
  3. Interact with your client’s point persons, such as in house counsel
  4. Conduct an internal investigation and audit
  5. Build and implement compliance program measures to reduce liability, prevent future violations, and ultimately settle cases


Farhad Alavi

Akrivis Law Group, PLLC

Farhad Alavi is Managing Partner of Akrivis Law Group, PLLC. His practice focuses on international and domestic corporate matters and complex trade issues (including U.S. sanctions, export controls, anti-corruption regulations, and compliance), as well as multinational investment, banking & finance. Mr. Alavi’s clients include major multinational companies around the world, small and medium businesses, and high net worth individuals. He is also an Adjunct Professor of Law at Georgetown University Law Center.

Mr. Alavi previously practiced in several prominent law firms in Washington, most notably Baker & McKenzie LLP and Holland & Knight LLP, where he also had a dual, concurrent appointment in the firm’s Abu Dhabi, United Arab Emirates (UAE) office. At Baker & McKenzie, he practiced mainly in the fields of U.S. trade as well as oil and gas / project finance matters.

Mr. Alavi has vast experience in international sanctions, export controls, customs, and the Foreign Corrupt Practices Act (FCPA). His U.S. sanctions experience includes those against Iran, Cuba, Myanmar (Burma), Sudan, Syria, and North Korea, with emphasis on those regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Mr. Alavi is often quoted and/or cited in major international and trade publications around the world such as The New York Times, Financial Times, The Wall Street Journal, Washington Post, and Georgetown Journal of International Law, and has appeared on the BBC, Al Jazeera English, CCTV America, BBC Persian, Voice of America (VOA) Persian, and Al-Hurra, among others. He also regularly lectures on trade compliance matters in the United States and abroad.

In addition to trade compliance, Mr. Alavi also advises clients on enforcement/defense matters related to U.S. sanctions and export controls. These include criminal defense litigation matters related to violations of the International Emergency Economic Powers Act (IEEPA). He has also provided expert opinion for litigation on issues relating to the application of U.S. sanctions laws.

Mr. Alavi’s corporate law experience spans a range of such areas such as international joint venture, distribution, and financing agreements. He has particular experience in the oil & gas, defense, finance, health care, food, and hospitality industries, and is especially well-versed in issues related to projects and dealings involving key emerging and frontier markets, including China, Latin America, and the MENA region, with emphasis on the Gulf Cooperation Council (GCC) states, as well as on Sharia-compliant financing.

Mr. Alavi received his LL.M. in Banking & Financial Law from Boston University School of Law, where he served on theAnnual Review of Banking and Financial Law journal. He received his J.D. from George Mason University School of Law. During law school, he studied at University College London (UCL) and the Johns Hopkins University School of Advanced International Studies (SAIS), and interned at the Organization of Economic Cooperation and Development (OECD). Mr. Alavi received his B.A. in Economics and International Relations from Tufts University.

Born and raised in Virginia, Mr. Alavi maintains native fluency in Persian (Farsi), is fluent in Spanish, and has knowledge of German and Arabic. He also maintains the U.S. Sanctions weblog. Mr. Alavi has served multiple terms on the national Board of Directors of the Iranian-American Bar Association (IABA).


Carolyn H.


Marilyn S.

Thanks for making complex subject accessible.

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$ 59 Criminal Law, International Law, and Business, Corporate, & Securities Law In Stock


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