Iran sanctions reimposed and in full effect

Iran sanctions reimposed and in full effect
 Iran sanctions reimposed and in full effect

As of November 5, 2018, all of the US sanctions that were lifted or waived in connection with the Joint Comprehensive Plan of Action (JCPOA), the 2016 nuclear deal among the United States and its allies and Iran, have been reimposed and are in full effect.

 

 

As a result, non-US companies can be subject to significant sanctions, and even blocked from accessing US markets, if they engage in certain activities involving Iran or certain Iranian persons (as well as entities owned 50 percent or more by such persons), related to key sectors, such as energy; banking; shipping and shipbuilding; and insurance, reinsurance, and underwriting.

In addition, limited relief that was provided to US companies and their non-US subsidiaries during the JCPOA and subsequent wind-down periods has been revoked. Further, hundreds of persons who had been removed from the sanctions lists maintained by the US Department of the Treasury, Office of Foreign Assets Control (“OFAC”) have been redesignated, which affects both US companies, which can face significant civil and criminal penalties for dealing with designated persons, and non-US companies, which can be subject to blocking sanctions for engaging in significant transactions with such persons. OFAC announced that “these are the toughest US sanctions ever imposed on Iran” and “[t]he United States is engaged in a campaign of maximum financial pressure on the Iranian regime and intends to enforce aggressively these sanctions that have come back into effect.”

The implications of these developments are also troubling for EU operators who, as a result of the amended EU Blocking Regulation that came into effect on August 7, 2018, are facing the difficult choice of complying with EU law or the reimposed US sanctions.

 

Read more: Norton Rose Fulbright

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