ITSR · Iran OFAC Sanctions · Dubai

Iran Sanctions Lawyer
in Dubai — ITSR Expert

Dr. Shaun Gregory Morgan is a leading iran sanctions lawyer in Dubai, advising UAE corporations, banks, and trading companies on OFAC Iran sanctions compliance, ITSR enforcement defense, and specific license applications. Senior partner counsel from Emirates Towers, Level 42.

Consult an Iran Sanctions Lawyer All OFAC Services
200+
OFAC Matters
$0
In Client Penalties
15+
Iran OFAC Licenses Approved
20+
Years Experience
Dr. Shaun Gregory Morgan — Iran Sanctions Lawyer Dubai
FRANKLIN MORGAN LAW · DUBAI
Shaun Gregory Morgan
Iran Sanctions Lawyer Dubai · CEO & Managing Partner
Your Counsel

Dr. Shaun Gregory Morgan

Dr. Shaun Gregory Morgan is the leading Iran sanctions lawyer in Dubai, advising UAE, GCC and international clients on OFAC ITSR compliance, SDN list screening, OFAC specific license applications, and Iran-related enforcement defense.

200+ OFAC matters handled · $0 in civil monetary penalties secured · 15+ OFAC specific licenses approved for Iran matters · Emirates Towers Level 42, Dubai International Financial Centre.

LLM Northwestern MSc LSE 2000 NY Bar 1210887 20+ Years $0 Penalties
Schedule Consultation → Full Profile
Managing Partner
200+
OFAC Matters Handled
$0
In Client Penalties
15+
Iran OFAC Licenses
20+
Years of Experience
Iran Sanctions Compliance

Why You Need an Iran Sanctions Lawyer in Dubai

The Iranian Transactions and Sanctions Regulations (ITSR), codified at 31 C.F.R. Part 560, impose one of the most comprehensive sanctions regimes administered by OFAC. The ITSR prohibits virtually all trade, financial, and service transactions involving Iran, Iranian persons, and the Government of Iran. For UAE businesses, civil penalties for a single ITSR violation can reach $1,437,153 per transaction — and criminal liability can follow the most egregious violations. Ignorance of the ITSR is not a defense.

The UAE's unique position as a global trade hub — and Dubai's geographic proximity to Iran — creates persistent Iran sanctions exposure for UAE businesses that no compliance program can entirely eliminate without expert legal guidance. Dubai's free zones, including JAFZA, RAKEZ, and DMCC, have been identified by OFAC as high-risk environments for Iranian re-export and transshipment activity. Secondary sanctions provisions mean that UAE companies with no US ownership, no US employees, and no US dollar transactions can still be designated by OFAC for dealing with Iranian SDN-listed counterparties — with devastating consequences for their banking relationships and international business.

As a leading iran sanctions lawyer in Dubai, Dr. Shaun Gregory Morgan advises UAE businesses across the full spectrum of ITSR compliance: designing and testing Iran risk management programs, advising on SDN and OFAC 50% Rule screening protocols, preparing OFAC specific license applications for humanitarian and other permitted categories, and defending UAE clients in OFAC enforcement proceedings. His practice covers every sector — banking, trading, real estate, logistics, and professional services — where ITSR exposure is most acute.

Dr. Morgan holds an LLM from Northwestern University School of Law and an MSc in Economics from the London School of Economics (LSE, 2000), and is admitted to the New York State Bar (No. 1210887). With over 20 years of legal practice in Dubai and New York, he combines US-qualified OFAC expertise with deep knowledge of the UAE commercial environment — a combination that no Washington DC-based firm can replicate. His track record of $0 in client penalties across 200+ OFAC matters demonstrates that quality of counsel makes an irreplaceable difference in Iran ITSR outcomes.

What We Do

Iran Sanctions Services

Comprehensive ITSR compliance and Iran OFAC enforcement defense for UAE corporations, banks, and trading companies from Emirates Towers, Dubai.

Iran ITSR Compliance Programs

We design, implement, and test comprehensive Iran ITSR compliance programs tailored to your industry, business model, and risk profile. From SDN screening protocols and customer due diligence frameworks to policy manuals and staff training, we build programs that satisfy OFAC's compliance commitment framework and withstand ITSR enforcement scrutiny.

OFAC Specific License Applications

For UAE businesses requiring OFAC authorization to engage in otherwise-prohibited Iran-related activity, we prepare and submit specific license applications with compelling legal arguments, factual records, and targeted policy advocacy. Our track record includes more than 15 approved OFAC licenses across Iran humanitarian, wind-down, and personal remittance categories.

Iran Sanctions Enforcement Defense

If you receive an OFAC subpoena, notice of investigation, or pre-penalty notice related to Iran ITSR violations, our enforcement defense team responds immediately and strategically. We leverage voluntary self-disclosure, cooperation credit, and comprehensive remediation programs — achieving $0 in client penalties across 200+ OFAC matters handled.

Secondary Sanctions Risk Assessment

We conduct bespoke secondary sanctions risk assessments for UAE businesses operating in sectors with Iran-adjacent exposure — including oil and gas, metals, banking, shipping, and trade finance. Our assessments identify secondary sanctions exposure under CAATSA, CISADA, and the Iran Freedom and Counter-Proliferation Act, and recommend concrete mitigation strategies.

Free Zone Iran Sanctions Audit

UAE free zones — including JAFZA, RAKEZ, DMCC, and Dubai South — present elevated Iran re-export and transshipment risk. We conduct privileged Iran sanctions audits of free zone operations, identify Iranian beneficial ownership risks, and implement enhanced controls that reduce OFAC enforcement exposure while maintaining business efficiency.

Blocked Property & SDN Guidance

When a UAE business discovers blocked Iranian property, an SDN-linked transaction, or a customer with Iranian SDN beneficial ownership, the legal obligations are immediate and complex. We provide urgent guidance on blocking obligations, reporting requirements, and strategic options — including voluntary self-disclosure and remediation — to minimize OFAC enforcement exposure.

UAE Risk Profile

Top Iran Sanctions Risks for UAE Businesses

Dubai's commercial position creates three categories of Iran ITSR exposure that every UAE business must proactively manage.

Free Zone Re-Export Liability

JAFZA, RAKEZ, and DMCC have been flagged by OFAC as high-risk environments for Iranian re-export and transshipment of controlled goods and technology. UAE free zone operators face ITSR liability for exporting US-origin or foreign-made controlled items to Iran through Dubai distribution channels — even without knowledge of the ultimate Iranian end-user.

Banking & Dollar Payment Risk

UAE banks and businesses that process US dollar transactions through US correspondent banks face immediate blocking of Iran-connected payments. Correspondent banking relationships — the lifeline of UAE international trade finance — can be terminated entirely if OFAC identifies persistent Iran sanctions violations. Maintaining correspondent access requires robust ITSR compliance infrastructure.

Iranian Beneficial Ownership

Under OFAC's 50% Rule, any UAE company 50% or more owned by an Iranian SDN designee is itself treated as blocked — regardless of whether it appears on the SDN list. UBO screening failures in Dubai real estate, free zone company formation, and trade finance represent the highest-volume source of Iran ITSR apparent violations in the UAE market today.

Our Methodology

How We Protect UAE Clients from Iran Sanctions Risk

A structured four-step process delivers Iran ITSR compliance programs that satisfy OFAC's requirements and withstand enforcement scrutiny.

1

Iran Risk Assessment

We conduct a privileged Iran sanctions risk assessment of your business operations, counterparty relationships, supply chains, and financial transactions — identifying all material ITSR exposure across your UAE and international activities.

2

SDN & ITSR Screening

We design and implement rigorous SDN screening and OFAC 50% Rule UBO analysis protocols, covering all customer categories, transaction types, and counterparty relationships — including enhanced screening for free zone and Iranian-nexus trade flows.

3

Compliance Program Design

We build a bespoke Iran ITSR compliance program — including written policies, escalation procedures, transaction monitoring controls, and staff training — calibrated to your risk profile and designed to satisfy OFAC's five essential components of an effective compliance program.

4

Ongoing Monitoring

Iran sanctions regulations evolve rapidly. We provide ongoing monitoring of OFAC regulatory developments, SDN list updates, and enforcement trends — updating your Iran ITSR compliance program to maintain continuous alignment with OFAC's current expectations.

Your Counsel

Meet Dr. Shaun Gregory Morgan

Dubai's leading iran sanctions lawyer — 200+ OFAC matters, $0 in client penalties, 20+ years of ITSR expertise from Emirates Towers.

Dr. Shaun Gregory Morgan — Iran Sanctions Lawyer Dubai
Iran Sanctions Lawyer · Managing Partner · Franklin Morgan Law
Dr. Shaun Gregory Morgan
Iran Sanctions Lawyer & Managing Partner — Franklin Morgan Law

Dr. Shaun Gregory Morgan is Dubai's most experienced iran sanctions lawyer, with a practice dedicated to protecting UAE businesses, banks, and trading companies from ITSR enforcement risk. Operating from Emirates Towers, Level 42, Sheikh Zayed Road, Dubai, Dr. Morgan has handled more than 200 OFAC matters for UAE-based clients — achieving $0 in civil penalties and securing 15+ OFAC-specific licenses, including multiple Iran humanitarian and wind-down licenses. His LLM from Northwestern University School of Law and admission to the New York State Bar (No. 1210887) provide genuine US-qualified Iran sanctions counsel that no UAE lawyer without US legal qualifications can offer. Dr. Morgan's dual jurisdiction expertise — combining deep knowledge of UAE commercial law with mastery of ITSR regulations and OFAC enforcement practice — is the decisive advantage his clients bring to every Iran sanctions matter.

LLM — Northwestern University School of Law
MSc Economics — LSE (2000)
NY Bar No. 1210887
Emirates Towers, Level 42, Dubai
$113M DIAC Arbitration Award
Common Questions

Iran Sanctions FAQ for UAE Businesses

Yes. OFAC's Iran sanctions program (ITSR) has extraterritorial reach. UAE companies that facilitate transactions involving Iran, Iranian persons, or the Government of Iran can face civil penalties of up to $1,437,153 per violation — even without any US nexus, US persons, or US dollar transactions. Secondary sanctions provisions allow OFAC to penalize UAE entities that provide material support to Iranian SDN designees. Engaging an iran sanctions lawyer in Dubai immediately upon discovery of potential ITSR exposure is critical to minimizing enforcement risk.

The Iranian Transactions and Sanctions Regulations (ITSR), codified at 31 C.F.R. Part 560, are OFAC's primary Iran sanctions regulations. They impose a near-comprehensive embargo on dealings with Iran, Iranian persons, and the Government of Iran. For UAE businesses, the ITSR is particularly relevant because of Dubai's geographic proximity to Iran, the UAE's role as a global trade hub, and the persistent risk of Iranian re-export through UAE free zones. ITSR violations can result in civil penalties, SDN designation, and loss of US banking access.

Secondary sanctions allow OFAC to penalize non-US persons — including UAE companies — for certain dealings with Iran, even without any US connection. Under the Iran Freedom and Counter-Proliferation Act, CISADA, and other authorities, UAE entities that provide material support to Iranian SDN designees or engage in significant transactions in sanctioned Iranian sectors (energy, shipping, metals) can be cut off from the US financial system — effectively preventing them from processing US dollar payments globally. This risk makes consulting an iran sanctions lawyer in Dubai essential for any UAE business with Iran-adjacent trade flows.

Yes, in limited circumstances. OFAC issues specific licenses for categories including humanitarian transactions (food, medicine, medical devices), personal remittances, certain journalistic activities, and contractual wind-down arrangements. General licenses also authorize certain categories of Iran-related transactions without requiring individual applications. Obtaining an Iran-related OFAC specific license requires a comprehensive application demonstrating legal eligibility, policy justification, and detailed transactional information. Dr. Shaun Gregory Morgan has secured more than 15 OFAC licenses and is a leading iran sanctions lawyer in Dubai for license applications.

If a UAE company discovers it has an Iranian-nexus customer, it should immediately: (1) cease all new transactions with that customer pending legal review; (2) engage an experienced iran sanctions lawyer in Dubai to assess the nature and scope of the ITSR exposure; (3) preserve all relevant records under legal privilege; (4) evaluate whether voluntary self-disclosure to OFAC is strategically appropriate — a well-crafted VSD can reduce civil penalties by 50% or more; and (5) implement enhanced due diligence on the broader customer portfolio for similar Iranian-nexus exposure. Acting promptly and proactively is the single most important factor in minimizing OFAC enforcement consequences.

Under OFAC's 50% Rule, any entity that is 50% or more owned — directly or indirectly — by an SDN-designated person is itself treated as an SDN, even if the entity itself is not named on the list. For UAE businesses, this means that a UAE company with Iranian SDN beneficial ownership at or above the 50% threshold is automatically blocked — and dealing with it violates ITSR regulations. Robust UBO screening and ongoing beneficial ownership monitoring are essential elements of any Iran sanctions compliance program. An iran sanctions lawyer in Dubai can advise on implementing screening protocols that satisfy OFAC's expectations for UAE market conditions.

Expert Iran Sanctions Counsel in Dubai

Consult an Iran Sanctions Lawyer
in Dubai Today

Whether you face an ITSR enforcement action, need to build an Iran sanctions compliance program, or require an OFAC specific license — Dr. Shaun Gregory Morgan provides senior-partner iran sanctions counsel from the first call. 200+ OFAC matters. $0 in client penalties. Available 24/7 for urgent Iran ITSR matters.

Schedule Consultation About Dr. Morgan
Emirates Towers, Level 42, Sheikh Zayed Road, Dubai, UAE
+971 4 327 98 97
[email protected]