• GL
Choose your location?
  • Global Global
  • Australia
  • France
  • Germany
  • Ireland
  • Italy
  • Poland
  • Qatar
  • Spain
  • UAE
  • UK

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

We use cookies to give you the best user experience on our website. Please let us know if you accept our use of cookies.

Manage cookies

Your Privacy

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. We mainly use this information to ensure the site works as you expect it to, and to learn how we can improve the experience in the future. The information does not usually directly identify you, but it can give you a more personalised web experience.
Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change permissions. However, blocking some types of cookies may prevent certain site functionality from working as expected

Functional cookies

(Required)

These cookies let you use the website and are required for the website to function as expected.

These cookies are required

Tracking cookies

Anonymous cookies that help us understand the performance of our website and how we can improve the website experience for our users. Some of these may be set by third parties we trust, such as Google Analytics.

They may also be used to personalise your experience on our website by remembering your preferences and settings.

Marketing cookies

These cookies are used to improve and personalise your experience with our brands. We may use these cookies to show adverts for our products, or measure the performance of our adverts.