EPSILON ELECTRONICS, INC. v. US DEPT OF TREASURY

No. 16-5118.

857 F.3d 913 (2017)

EPSILON ELECTRONICS, INC., Appellant v. UNITED STATES DEPARTMENT OF the TREASURY, Office of Foreign Assets Control, et al., Appellees.

United States Court of Appeals, District of Columbia Circuit.

Decided May 26, 2017.


Attorney(s) appearing for the Case

Teresa N. Taylor argued the cause and filed the briefs for appellant.

Eric S. Volkman, Washington, DC, was on the brief for amicus curiae JPM Legal Advisors Worldwide Limited in support of appellant.

Lewis S. Yelin, Attorney, U.S. Department of Justice, argued the cause for appellees. With him on the brief were Benjamin C. Mizer, Principal Deputy Assistant Attorney General, and Douglas N. Letter and Sharon Swingle, Attorneys, Washington, DC.

Opinion concurring in part and dissenting in part filed by Senior Circuit Judge Silberman.


In 1995, President Clinton imposed trade sanctions against Iran that are enforced by the Office of Foreign Assets Control within the Department of the Treasury. OFAC is authorized to impose civil penalties against any person who exports goods to a third party who it has reason to know intends to send them to Iran. The principal...

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