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Implications for the Insurance, Reinsurance, and Brokerage Industry Under the JCPOA

By Guy Soussan & Jack Hayes on July 31, 2015
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Steptoe’s Guy Soussan and Jack Hayes recently published an article in Insurance Day about the implications for the insurance, reinsurance, and brokerage industry under the Joint Comprehensive Plan of Action (JCPOA) related to Iran.  There are five key points:

  1. Virtually all EU insurance-related sanctions would be removed.
  2. Some, but not all, US insurance-related sanctions would be removed – most sanctions applicable to US person insurers, reinsurers, and brokers apparently will remain in place.
  3. Entities outside the US that are owned or controlled by US persons would be licensed to conduct (specified) Iran business, but the scope of business to be authorized is not specified under the JCPOA, nor has the US government published guidance on this point.
  4. Lifting of sanctions is not immediate (or guaranteed based on the political dynamics involving a skeptical US Congress).
  5. Even if sanctions are lifted, due diligence and dealing with global financial institutions will be challenging for industry given that some targeted sanctions will remain.

Read the full article at Insurance Day (subscription required).

Photo of Guy Soussan Guy Soussan

Guy Soussan advises clients on various aspects of EU and French export control regulations, including controls and licensing regimes for both military and commercial products and technologies. His export practice covers compliance development and implementation, internal investigations, and enforcement matters, including voluntary disclosures.

Guy Soussan advises clients on various aspects of EU and French export control regulations, including controls and licensing regimes for both military and commercial products and technologies. His export practice covers compliance development and implementation, internal investigations, and enforcement matters, including voluntary disclosures. He also provides advice and assistance with EU economic sanctions targeting specific countries such as Iran, Libya, Syria, and most recently, Ukraine and Russia. His experience covers a wide range of industries, including manufacturing, energy, telecommunications, banking and insurance, petroleum and petro-chemicals, aerospace, and defense. He has conducted internal compliance audits, provided assistance on company compliance programs, and counseled clients on the application of the rules to specific transactions.

Read Guy’s full bio.

Read more about Guy SoussanEmail
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Photo of Jack Hayes Jack Hayes

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and…

Jack Hayes has extensive experience providing clients with advice and assistance under ITAR and EAR, as well as US economic sanctions and anti-boycott regulations. Jack frequently handles complex export control matters, including voluntary disclosures, internal investigations of apparent export control violations, pre-closing and post-closing acquisition export compliance due diligence, export control audits, and assessments of compliance obligations and risks in accordance with relevant international trade regulations. He also provides guidance on brokering requirements and reporting obligations for certain fees, commissions, and political contributions related to sales of defense articles and defense services, prepares export and reexport license and agreement applications for submission, undertakes commodity jurisdiction and export classification analyses of items and services under the ITAR and EAR, drafts registration material change notifications, and develops compliance policies, programs, and training materials.

Read Jack’s full bio.

Read more about Jack HayesEmail
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  • Posted in:
    Government and Public Policy
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

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