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Update: Iran Sanctions

04 December 2018

It is a common misconception that only Americans must comply with United States sanctions. They potentially apply to everyone. International organisations, including some with no connection to the United States, have been prosecuted for breaching U.S. sanctions.

Latest developments regarding Iran

On 8 May 2018, U.S. President Donald Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action, otherwise known as the JCPOA or the “Iran nuclear deal”.

Businesses were given 180 days to wind down their trade with Iran. 4 November 2018 marked the final day of the wind down period.

The United States has now effectively reversed the liberalising actions that it took under the JCPOA regarding Iran trade.


The net effect is:

  • United States persons, natural and corporate, remain almost entirely prohibited from conducting Iranian business.
  • 700+ Iranian persons, organisations and companies are now “blacklisted” by the U.S. authorities.
  • “Secondary sanctions” are back in place, meaning that non-U.S. persons potentially face prosecution when doing business with Iran.
  • It is an offence to cause a U.S. person to breach Iranian sanctions. This might include an international organisation involving its U.S. staff, U.S. banks or U.S. managing agents/contractors in Iran business.
  • OFAC, the U.S. sanctions regulator, has announced that its sanctions against Iran will be “aggressively enforced”.

Penalties for breaching U.S. sanctions can be substantial. Violators can also end up being locked out of U.S. markets and may find business partners reluctant to deal with them, for fear of antagonising the U.S. authorities.


How we can help

We can:

  • Advise you how U.S. sanctions and related laws apply to your organisation;
  • Help you understand the exposures & practical difficulties of conducting Iran business;
  • Explain what you can do to manage the risks;
  • Train your staff regarding U.S. sanctions on Iran;
  • Prepare policies and contractual wordings that account for U.S. sanctions on Iran;
  • Provide bespoke advice on any particular transaction with a connection to Iran.

Further Reading