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About Saam Borhani

Saam is the manager of Borhani & Pejman's OFAC sanctions practice department. He began his career on the defense team at the Special Court for Sierra Leone, working behind the scenes of one of the most important international criminal cases in a generation. With a graduate degree in international diplomacy in addition to his law degree, Saam has extensive skills in negotiation that he utilizes on behalf of his clients.

Why Boeing kept Iran dealings under the radar

By |April 17th, 2016|


Published in

By Saam Borhani, Esq.
Barely a week after the Jan. 16 lifting of nuclear-related sanctions on Iran, Tehran hosted its first international business summit in years. The event, sponsored by the Centre for Aviation (CAPA), brought together 400 executives of the global aviation industry to re-establish links with their Iranian counterparts after a decades-long […]

Gazprom field hit by new US sectoral sanctions on Russia.

By |August 8th, 2015|

Last week saw further activity expanding US sectoral sanctions against Russian industry. The sanctions against Russia, developed as a reaction to the invasion of Crimea, differ from other American sanctions in that they target specific sectors of the Russia economy. We see the Russian sanctions as a test case to see if such sectoral sanctions work and if […]

Snapback and grandfathering old contracts. Treasury’s view of the issue made clear.

By |August 5th, 2015|

Much debate on the Iran Deal has centered around the utility of the “snapback” of sanctions in case Iran cheats. There is language in the JCPOA (Paragraph 37)  that has led some to believe that contracts signed before a hypothetical “snapback” would be grandfathered in and allowed to continue as restrictions on new trade would […]

Where are sanctions headed after the JCPOA?

By |August 4th, 2015|

Sanctions are in vogue. In an era when American military intervention has betrayed its limitations and the world is interconnected through trade, the concept of cutting off a bad actor from making money is the ultimate silver bullet. No American soldiers would have to be deployed, the costs to American taxpayers is generally tiny, and sanctions […]

OFAC issues a reminder to US small businesses about sanctions, by means of a $82,000 penalty.

By |July 29th, 2015|

For any American small businesses thinking that Iran is open for business without the need for sanctions compliance, OFAC just set the record straight.

The Office of Foreign Assets has stuck Massachussettes based Blue Robin, Inc. with a $82,000 penalty for contracting with an Iranian IT company to develop web-based systems and apps.

OFAC’s action was taken […]

What American companies need to know about the JCPOA.

By |July 28th, 2015|


If you read news reports both for and against the Iran Deal, you might just believe that the 35-year-old sanctions regime against Iran has evaporated and American business will be re-entering the country en masse. This belief, spreading quickly in both Washington and Tehran is dangerous, both in terms of increasing expectations for trade and […]

The nuclear deal and U.S. business

By |July 26th, 2015|

Since the JCPOA was signed, international media has been overflowing with breathless accounts of big-name multinationals plotting their return to Iran. From Apple to Total to even McDonald’s, it seems like big business is ready for a gold rush of unimaginable proportions.

The bad news: it’s a little more complicated than that of a free-for-all, especially […]

Will the nuclear deal ease Iranian-Americans’ banking woes?

By |July 26th, 2015|

Perhaps the most frustrating aspect of OFAC’s administration of Iran sanctions, for Iranian-Americans at least, has to do with banking restrictions. American citizens and residents of Iranian descent have reported frozen U.S. bank accounts, proceeds from inheritances unable to be transferred to the U.S. from Iran, and hopping between the two countries with cash stuffed […]