Doing Business in Iran Amid Increasing Sanctions

In May 2018, the U.S. withdrew from the Iran nuclear deal, the Joint Comprehensive Plan of Action (JCPOA). Following withdrawal, U.S. sanctions waived under the JCPOA were reimposed. As of Nov. 5, 2018, U.S. sanctions had returned to pre-JCPOA levels. The reimposition of sanctions limits what business can be conducted in Iran by U.S. companies and their subsidiaries and poses risks for non-U.S. companies doing business with targeted industries in Iran.

Few transactions will not raise the risk of U.S. secondary sanctions for non-U.S. persons. Although the United States did grant supply reduction exceptions to certain countries regarding the purchase of oil from Iran, the exemptions are temporary and to fewer countries compared to pre-JCPOA exemptions.

On the EU side, the new blocking regulation poses risks for companies that decide to terminate business with Iran to avoid U.S. sanctions, and sanctions not terminated under the JCPOA remain in force. Both U.S. and EU authorities closely monitor business activities with Iran and are ramping up enforcement efforts. Failure to comply with these regulations can be costly.

Given the complex regulatory environment, it is essential for companies and their counsel to understand the applicable sanctions and export control hurdles and the steps that are necessary for compliance.

Listen as our authoritative panel addresses the evolving sanctions situation in Iran, what sanctions and countermeasures are in place, and what this means for companies currently doing or wanting to do business in Iran. The panel will discuss what general or specific licenses may be available when dealing with Iran, as well as applicable export controls and related issues.

1. Sanctions
   1. U.S. new and reimposed sanctions
   2. U.S. supply reduction exceptions
   3. EU sanctions
   4. EU blocking regulation
2. Licenses
   1. Termination of U.S. general licenses and licensing policies implemented under JCPOA
   2. Current U.S. general licenses and licensing policy
   3. EU/U.K. licensing policy
   4. Authorizations available under the EU blocking regulation
3. Export controls and related issues

The panel will review these and other key issues:

• What business activities are permissible for U.S. companies concerning Iran?
• What business activities expose non-U.S. companies to U.S. secondary sanctions?
• What EU sanctions remain in place and is this likely to change post-BREXIT?
• What constraints does the new EU blocking regulation impose on EU companies, including companies owned or controlled by U.S. persons?
• Will the blocking regulation continue to apply to U.K. companies post-BREXIT?
• What steps should companies take to promote sanctions and export control compliance concerning Iran?