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On May 8, 2018, the President announced his decision to withdraw from the Joint Comprehensive Plan of Action (the “JCPOA”, also known as the Iran nuclear deal), and to begin re-imposing, following a wind-down period, the U.S. nuclear-related sanctions against Iran that had previously been lifted. Importantly, this action mostly involves “secondary” sanctions – actions that the U.S. may take against foreign persons who engage in transactions involving Iran. Such sanctions, if implemented, may restrict access by foreign entities to U.S. exports as well as the U.S. financial system, effectively isolating these companies from the global economy. The scope of activities covered by U.S. secondary sanctions is far-ranging, and the statutes establishing these sanctions are extremely complex. Moreover, interpretive guidance issued by the Office of Foreign Assets Control – the agency of the U.S. government in charge of administering these sanctions – has done little to clarify these opaque requirements.
Further complicating matters for European companies, the European Commission has issued a “blocking” regulation in response to the U.S. action that explicitly prohibits entities subject to European jurisdiction from complying with the U.S. sanctions against Iran. Compliance with U.S. law risks sanctions under European law, and vice versa, seemingly leaving these companies with no good options.
In this One Hour Briefing, Dr. Lothar Harings of the German law firm Graf von Westphalen and Brett Ian Harris of the U.S. firm Pisani & Roll LLP review the U.S. secondary sanctions against Iran and discuss the impact of these sanctions on foreign persons. Offering both U.S. and EU compliance perspectives, this joint presentation will cover the following topics:
- Economic sectors impacted by U.S. secondary sanctions
- Conduct subject to U.S. secondary sanctions
- Potential U.S. sanctions applicable in the event of a violation
- Activities permitted after the end of the wind down period
- Summary of current EU sanctions against Iran
- Effect of EU blocking regulation on conduct of European companies
- Impact of sanctions on U.S. subsidiaries in Europe
- Compliance strategies for those European companies engaging in transactions with Iran
- An overview of recent developments in each of these areas
Program Level: Update
Intended Audience: Law firm attorneys, in house counsel, compliance managers, banking industry participants, ACAMS, international trade industry professionals, accounting professionals and policy experts inside or outside of government
Advanced Preparation: None