On August 9, 2019, the United States Court of Appeals for the Second Circuit issued in an opinion in the United States v. Assa case, Case No. 17-3658. In this case, the Second Circuit affirmed in part, vacated in part, and remanded for further proceedings a district court decision regarding civil forfeiture of a foreign state’s property. The district court had determined that Assa Co. Ltd. and Assa Corporation were serving as a front for the central bank of Iran, and therefore as a front for the Iranian government, and that Assa was providing services to Iran in violation of U.S. sanctions on Iran. The district court ordered that the U.S. government had authority under civil forfeiture laws to seize property of Assa, including a 36-story building located on 5thAvenue in Manhattan and other real property and bank accounts. On appeal, Assa argued that the district court lacked subject matter jurisdiction due to immunity conferred to foreign states by the Foreign Sovereign Immunities Act. The Court held that “the district court had jurisdiction because the Foreign Sovereign Immunities Act does not foreclose in rem civil-forfeiture suits against a foreign state’s property. However, the [district] court abused its discretion by sua sponte resolving the statute-of-limitations issue without providing the Defendants-Appellants notice or opportunity to defend themselves.”