Second Circuit Rejects Forfeiture of Building Controlled by Government of Iran in Violation of Economic Sanctions

On July 20, 2016, the Second Circuit overturned the District Court for the Southern District of New York’s decision to forfeit an approximately $1 billion dollar New York City office building on the grounds that the building was owned or controlled by the Government of Iran, in violation of a 1995 Executive Order (and subsequent OFAC controls implementing the order) prohibiting U.S. persons from dealing with any “instrumentality” of the Iranian government.