Iran sanctions lifted as part of the Iran Nuclear Deal went back into effect today, November 5, 2018. Companies seeking or performing US government contracts should take this opportunity to confirm that none of their international vendors, suppliers, and subcontractors are on the Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons list.
As discussed in more detail in this blog post by our firm’s Export Controls and Economic Sanctions team, the reimposed sanctions extend to a wide range of individuals and companies, including those in the petroleum, shipping, and shipbuilding sectors, as well as to non-U.S. financial institutions and insurance companies that facilitate transactions with SDNs.
Further reading on this topic—
OFAC’s Specially Designated Nationals and Blocked Persons List (SDN)
OFAC’s Press Release on Iran Sanctions
OFAC Amendments to Iranian Transactions and Sanctions Regulations (Nov. 2, 2018)