On November 5, the United States reimposed the final tranche of sanctions on Iran, which had been lifted pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) in 2016. The vast majority of these sanctions are “secondary sanctions,” being those which target non-U.S. persons and companies even where there is no U.S. nexus (e.g. the use of USD; U.S.-persons; or U.S. goods). The secondary sanctions cover a variety of goods and services, as well as prohibitions on dealings with certain individual persons and entities. While exceptions for humanitarian goods, agricultural products, medicine and medical devices remain in place, entities may find doing even this kind of business in Iran more challenging due to restrictions on the Iranian banking industry. When taking decisions about whether to enter into or continue Iran-related trade, EU companies must also weigh the risk of circumventing the EU’s so-called “blocking” statute. To read our summary of the reimposed sanctions, visit reedsmith.com.
