Despite Sanctions on Iran

Size: px
Start display at page:

Download "Despite Sanctions on Iran"

Transcription

1 Despite Sanctions on Iran Most of us can do business here! By Scott Antel, Hotel & Leisure Partner, Berwin Leighton Paisner LLP, Dubai 8 February 2017

2 The Joint Comprehensive Plan of Action (JCPOA) The Joint Comprehensive Plan of Action was agreed between China, France, Germany, Russia, UK, US, EU and Iran on the 14 th July This lifted all nuclear-related economic and financial sanctions against Iran from Implementation Day (16 January 2016) when the IAEA confirmed Iran s compliance. Potential snap back for non-compliance, but will not be retroactive (e.g, 180 days wind down ).

3 EU and US sanctions The JCPOA lifted sanctions adopted at the EU level on Implementation Day. U.S. secondary sanctions have been lifted under the JCPOA, however U.S. primary sanctions remain in place. Secondary sanctions These apply to non- U.S. persons undertaking business entirely outside of U.S. jurisdiction Primary sanctions These apply to U.S. persons. The U.S. domestic trade embargo on Iran remains in place, with some exceptions. No direct/indirect sale of US origin: goods/technology/services - 10% US content = US Origin - No US Person Involvement But Authorised Business Support Systems Exception (e.g., US origin PMS used globally)

4 Continued application of U.S. sanctions to non-u.s. Persons persons Transactions Transactions designed to evade U.S. sanctions or which could cause a U.S. person to violate sanctions Involvement with listed bodies Sanctions continue to apply to dealings with certain sanctions targets, including the Iranian Revolutionary Guard Corps. Employees Sanctions continue to apply to U.S. persons who are employed in non-u.s. operations which are conducting business with Iran. Dollar clearing restrictions Dollar clearing restrictions through US/UK clearing system.

5 EU Sanctions On implementation day, the EU lifted all its economic and financial sanctions. These include sanctions on: 6 Software 5 Metals 1 Banking, insurance SWIFT access Sanctions lifted: 4 Gold, precious metals, banknotes, coinage 2 Oil, gas, petrochemical 3 Shipping, shipbuilding, transport, Services

6 Other Countries Many countries do not have formal sanctions regime, but, as member states, comply with UN Security Council Sanctions. For example, the UAE follows UN Sanctions and applies EU/US sanctions on an ad hoc basis.

7 Remaining Sanctions under UN/EU/US rules: Sanctions remain against certain entities that are related to Iran s support for: a) Terrorism. b) Nuclear proliferation. c) Human rights abuses. The sale, supply or export to Iran of, or investment in businesses manufacturing: a) Military goods and technology b) Missile-related goods and technology Transaction with listed persons ( SDNs ) of EU/UN/US

8 What Constitutes due diligence compliance Sensitive or duel use goods seek clearance Checking the SDN list is not enough. - Reasonable KYC due diligence Iranian counterparties should be prepared for such DD requests.

9 What about the tempestuous 7 y/o man child? The JCPOA is not a binding treaty obligation, but a set of political commitments i.e. it can be withdrawn by any signatory. But any reneging party must answer to 8 other signatories!

10 Finally: Sanctions rules very facts and circumstances driven. Always get specific advice regarding your project.

Q&A - JCPOA of 14 July 2015

Q&A - JCPOA of 14 July 2015 Iran sanctions lift On July 14, 2015, the EU, U.S., Russia, China, France, UK and Germany agreed with Iran on a Joint Comprehensive Plan of Action (JCPOA) Q&A - JCPOA of 14 July 2015 As an exporter, what

More information

Credendo Client Memo Snap-back of international sanctions regime against Iran April 2017

Credendo Client Memo Snap-back of international sanctions regime against Iran April 2017 Introduction Credendo Client Memo Snap-back of international sanctions regime against Iran April 2017 Upon implementation of the Joint Comprehensive Plan of Action ( JCPOA ) on 16 January 2016 ( Implementation

More information

Iran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions

Iran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions Iran Sanctions Relief: Opportunities and Challenges for US and EU Financial Institutions 8 October 2015 Although US and EU sanctions targeting Iran are not likely to be lifted before early 2016, there

More information

Doing Business with Iran

Doing Business with Iran Doing Business with Iran Sanctions-related Risks and Challenges ACAMS Germany Chapter Event - Sanctions Naidira Alemova-Goeres 9 June 2016 Contents 1 2 3 Joint Comprehensive Plan of Action US Nexus & Due

More information

International Trade Alert

International Trade Alert International Trade Alert January 21, 2016 If you read one thing While many of the U.S. and EU sanctions against Iran have been lifted, the U.S. and EU sanctions regimes have not been terminated, and substantial

More information

U.S. SUSPENDS NUCLEAR-RELATED SECONDARY SANCTIONS AGAINST IRAN

U.S. SUSPENDS NUCLEAR-RELATED SECONDARY SANCTIONS AGAINST IRAN CLIENT ALERT: U.S. SUSPENDS NUCLEAR-RELATED SECONDARY SANCTIONS AGAINST IRAN January 19, 2016 INTRODUCTION On January 16, 2016, the International Atomic Energy Agency ( IAEA ) issued a report confirming

More information

IRAN SANCTIONS UPDATE

IRAN SANCTIONS UPDATE IRAN SANCTIONS UPDATE AFTER IMPLEMENTATION DAY Irvine Chamber of Commerce Webinar March 24, 2016 IEBP Global Trade Compliance, Christel Vilogron Christel Vilogron 2016 JCPOA IMPLEMENTATION DAY January

More information

Issued on May 8, 2018 Updated on June 27, 2018

Issued on May 8, 2018 Updated on June 27, 2018 This document is explanatory only and does not have the force of law. Please see particularly the legally binding provisions cited below governing the sanctions. This document does not supplement or modify

More information

EXECUTIVE ORDER RE-IMPOSES U.S. SECONDARY SANCTIONS AGAINST IRAN

EXECUTIVE ORDER RE-IMPOSES U.S. SECONDARY SANCTIONS AGAINST IRAN CLIENT ALERT: EXECUTIVE ORDER RE-IMPOSES U.S. SECONDARY SANCTIONS AGAINST IRAN August 14, 2018 Introduction On May 8, 2018 President Trump announced that the United States was withdrawing from the Joint

More information

Doing Business with Iran: The EU Sanctions Regime

Doing Business with Iran: The EU Sanctions Regime Doing Business with Iran: The EU Sanctions Regime Chamber of Commerce of Hasselt 30 March 2017 Guy Soussan and Jack Hayes Overview of Presentation 1. Basic overview of EU economic sanctions 2. EU sanctions

More information

How to continue doing business with Iran despite the re-imposition of US Sanctions?

How to continue doing business with Iran despite the re-imposition of US Sanctions? How to continue doing business with Iran despite the re-imposition of US Sanctions? Austrian Chamber of Commerce Presented by Sophie Gabillot, Head of Iran & Sanctions Desk at CAA s.gabillot@caa-avocats.com

More information

UNITED STATES WITHDRAWS FROM JCPOA AND REIMPOSES SECONDARY SANCTIONS AGAINST IRAN

UNITED STATES WITHDRAWS FROM JCPOA AND REIMPOSES SECONDARY SANCTIONS AGAINST IRAN MAY 10, 2018 CIRCULAR NO. 15/18 TO MEMBERS OF THE ASSOCIATION Dear Member: UNITED STATES WITHDRAWS FROM JCPOA AND REIMPOSES SECONDARY SANCTIONS AGAINST IRAN On May 8, 2018, President Trump decided to withdraw

More information

International Trade Compliance and Enforcement Bulletin

International Trade Compliance and Enforcement Bulletin International Trade Compliance and Enforcement Bulletin February 8, 2016 Changes to Iran Sanctions Provide a Few Business Opportunities, but Many Hurdles Authors: On January 16, 2016, the International

More information

International Issues in Government Contracting. Addie Cliffe Carlton Greene Yuan Zhou

International Issues in Government Contracting. Addie Cliffe Carlton Greene Yuan Zhou International Issues in Government Contracting Addie Cliffe Carlton Greene Yuan Zhou Agenda I. Introduction II. III. IV. Supply Chain Concerns Foreign Investment & M&A Developments in Economic Sanctions

More information

KIRKLAND ALERT. Iran Sanctions: A New Era Announced. Implementation Day Summary of Changes and Remaining Restrictions. U.S. Lifting of Sanctions

KIRKLAND ALERT. Iran Sanctions: A New Era Announced. Implementation Day Summary of Changes and Remaining Restrictions. U.S. Lifting of Sanctions KIRKLAND ALERT January 2016 Iran Sanctions: A New Era Announced On January 16, 2016, the U.S. and EU announced that a number of sanctions on Iran have been lifted under the Joint Comprehensive Plan of

More information

Doing Business in Iran Amid Evolving Sanctions: Leveraging New Opportunities While Ensuring Compliance

Doing Business in Iran Amid Evolving Sanctions: Leveraging New Opportunities While Ensuring Compliance Presenting a live 90-minute webinar with interactive Q&A Doing Business in Iran Amid Evolving Sanctions: Leveraging New Opportunities While Ensuring Compliance WEDNESDAY, MARCH 30, 2016 1pm Eastern 12pm

More information

PRESIDENT TRUMP ANNOUNCES U.S. WITHDRAWAL FROM THE IRAN NUCLEAR ACCORD AND RE-IMPOSITION OF WIDE-RANGING U.S. SANCTIONS

PRESIDENT TRUMP ANNOUNCES U.S. WITHDRAWAL FROM THE IRAN NUCLEAR ACCORD AND RE-IMPOSITION OF WIDE-RANGING U.S. SANCTIONS REGULATORY ADVISORY PRESIDENT TRUMP ANNOUNCES U.S. WITHDRAWAL FROM THE IRAN NUCLEAR ACCORD AND RE-IMPOSITION OF WIDE-RANGING U.S. SANCTIONS Kent Bressie, Robert Friedman, and Susannah Larson On May 8,

More information

US WITHDRA WAL FROM JCPOA: US SANCTIONS AND EU COUNTERMEASURES

US WITHDRA WAL FROM JCPOA: US SANCTIONS AND EU COUNTERMEASURES BRIEFING US WITHDRA WAL FROM JCPOA: US SANCTIONS AND EU COUNTERMEASURES MAY 2018 FOLLOWING NOVEMBER 4, 2018, US SANCTIONS THAT HAD BEEN LIFTED PURSUANT TO THE JCPOA WILL BE IN FULL EFFECT EU REMAINS IN

More information

US withdraws from Iran Nuclear Deal

US withdraws from Iran Nuclear Deal 14 May 2018 Indirect Tax Alert US withdraws from Iran Nuclear Deal EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts

More information

Doing business with Iran : sanctions risks for the shipping and logistics sector

Doing business with Iran : sanctions risks for the shipping and logistics sector Doing business with Iran : sanctions risks for the shipping and logistics sector Gerard Kreijen & Jochen Vankerckhoven LOYENS & LOEFF 1 Contents The lifting of EU sanctions against Iran The Iran sanction

More information

A. 1. What is Implementation Day? When does the lifting of sanctions under the JCPOA go into effect?

A. 1. What is Implementation Day? When does the lifting of sanctions under the JCPOA go into effect? This document is explanatory only and does not have the force of law. Please see particularly the legally binding provisions cited below governing the sanctions. This document does not supplement or modify

More information

Doing business in Iran EHSAN HOSSEINZADEH, ATTORNEY AT LAW & PARTNER AT EDUCATED LAWYERS LAW FIRM

Doing business in Iran EHSAN HOSSEINZADEH, ATTORNEY AT LAW & PARTNER AT EDUCATED LAWYERS LAW FIRM Doing business in Iran EHSAN HOSSEINZADEH, ATTORNEY AT LAW & PARTNER AT EDUCATED LAWYERS LAW FIRM Corporate structure in Iran Limited Liability Private Joint Stock Public Joint Stock Foreigner can possess

More information

SANCTIONS UPDATE: US SANCTIONS ON IRAN, 8 MAY 2018

SANCTIONS UPDATE: US SANCTIONS ON IRAN, 8 MAY 2018 MAY 2018 SANCTIONS SANCTIONS UPDATE: US SANCTIONS ON IRAN, 8 MAY 2018 President Trump announced on 8 May 2018 that the US would pull out of the JCPOA. He issued a National Security Presidential Memorandum

More information

COMMENTARY. Implementation Day Triggers Significant Changes to International Sanctions Against Iran UN SANCTIONS

COMMENTARY. Implementation Day Triggers Significant Changes to International Sanctions Against Iran UN SANCTIONS May 2016 COMMENTARY Implementation Day Triggers Significant Changes to International Sanctions Against Iran International sanctions on Iran changed drastically on Saturday, January 16, 2016. After months

More information

US sanctions against Iran

US sanctions against Iran US sanctions against Iran Page 1 Latest Update 6 March 2014 Author(s) Aleksandar Dukic - Hogan Lovells There appears to be some confusion in the media and among businesses regarding the scope of recent

More information

United States, EU, Other Global Powers Reach Comprehensive, Long-Term Nuclear Deal with Iran

United States, EU, Other Global Powers Reach Comprehensive, Long-Term Nuclear Deal with Iran United States, EU, Other Global Powers Reach Comprehensive, Long-Term Nuclear Deal with Iran Stage Set for Significant Sanctions Relief in Coming Months July 15, 2015 International Trade Controls On July

More information

President Trump Withdraws the United States from the Iran Nuclear Deal

President Trump Withdraws the United States from the Iran Nuclear Deal May 9, 2018 President Trump Withdraws the United States from the Iran Nuclear Deal U.S. and Non-U.S. Companies Now Face Deadlines for Winding Down Iran-Related Business On May 8, 2018, President Trump

More information

License safety-related repairs and inspections inside Iran for certain Iranian airlines.

License safety-related repairs and inspections inside Iran for certain Iranian airlines. Limited Lifting of Sanctions as part of the Recent Initial Agreement between the P5+1 (the United States, United Kingdom, France, Germany, Russia, China, facilitated by the European Union) and Iran November

More information

Annex II Sanctions-related commitments

Annex II Sanctions-related commitments Annex II Sanctions-related commitments The sequence of implementation of the commitments detailed in this Annex is specified in Annex V (Implementation Plan) to this Joint Comprehensive Plan of Action

More information

Sanctions Risk Management Symposium

Sanctions Risk Management Symposium Sanctions Risk Management Symposium September 18, 2017 1:30 PM 2:30 PM Navigating Increasingly Complex Sanctions Regimes Against Iran, Russia and Cuba: Hot Button Issues Elika Eftekhari Director of Trade

More information

Doing Business in Iran Amid Evolving Sanctions: Leveraging New Opportunities While Ensuring Compliance

Doing Business in Iran Amid Evolving Sanctions: Leveraging New Opportunities While Ensuring Compliance Presenting a live 90-minute webinar with interactive Q&A Doing Business in Iran Amid Evolving Sanctions: Leveraging New Opportunities While Ensuring Compliance WEDNESDAY, MARCH 30, 2016 1pm Eastern 12pm

More information

Sanctions Summary Matrix

Sanctions Summary Matrix Sanctions Summary Matrix A. Important notes This sanctions summary matrix summarises sanctions imposed by the European Union (EU) and United States of America (US) with regard to certain selected countries

More information

U.S. Economic Sanctions Iran Update March 2017

U.S. Economic Sanctions Iran Update March 2017 U.S. Economic Sanctions Iran Update March 2017 Presented by Kay Georgi, Arent Fox LLP LA / NY / SF / DC / arentfox.com Iran 2 Iran Key Things to Know about Sanctions Programs Recent changes in US and EU

More information

Implications of the EU Blocking Statute and U.S. sanctions on Iran

Implications of the EU Blocking Statute and U.S. sanctions on Iran Implications of the EU Blocking Statute and U.S. sanctions on Iran Advokatfirmaet Thommessen AS November 2018 On November 5, 2018, the U.S. Treasury Department s Office of Foreign Assets Control ( OFAC

More information

GUIDANCE RELATING TO THE LIFTING OF CERTAIN U.S. SANCTIONS PURSUANT TO THE JOINT COMPREHENSIVE PLAN OF ACTION ON IMPLEMENTATION DAY

GUIDANCE RELATING TO THE LIFTING OF CERTAIN U.S. SANCTIONS PURSUANT TO THE JOINT COMPREHENSIVE PLAN OF ACTION ON IMPLEMENTATION DAY U.S. DEPARTMENT OF THE TREASURY U.S. DEPARTMENT OF STATE GUIDANCE RELATING TO THE LIFTING OF CERTAIN U.S. SANCTIONS PURSUANT TO THE JOINT COMPREHENSIVE PLAN OF ACTION ON IMPLEMENTATION DAY Background...

More information

The Iran Nuclear Deal: What Does It Mean for US and EU Sanctions?

The Iran Nuclear Deal: What Does It Mean for US and EU Sanctions? Legal Update July 20, 2015 The Iran Nuclear Deal: What Does It Mean for US and EU Sanctions? The long-term nuclear deal with Iran announced on July 14 will result in changes to both the US and the EU sanctions

More information

United States Withdraws from the Joint Comprehensive Plan of Action with Iran

United States Withdraws from the Joint Comprehensive Plan of Action with Iran United States Withdraws from the Joint Comprehensive Plan of Action with Iran President Trump Announces Immediate Withdrawal from the Joint Comprehensive Plan of Action; Pre-JCPOA U.S. Sanctions Targeting

More information

Opportunities While Meeting Strict,

Opportunities While Meeting Strict, Presenting a live 90-minute webinar with interactive Q&A Latest Iran Sanctions: Leveraging New Opportunities While Meeting Strict, Rapidly Changing Requirements WEDNESDAY, MARCH 19, 2014 1pm Eastern 12pm

More information

The implementation of the Iran nuclear

The implementation of the Iran nuclear R E P R I N T RC & risk compliance & THE IRAN NUCLEAR DEAL: SANCTIONS RELIEF BRINGS COMPLIANCE CHALLENGES REPRINTED FROM: RISK & COMPLIANCE MAGAZINE JAN-MAR 2016 ISSUE RC & risk & compliance Visit the

More information

Practical sanctions - what are the pitfalls in claims handling. Does the lifting of sanctions relating to Iran make things easier or more complicated?

Practical sanctions - what are the pitfalls in claims handling. Does the lifting of sanctions relating to Iran make things easier or more complicated? Practical sanctions - what are the pitfalls in claims handling Does the lifting of sanctions relating to Iran make things easier or more complicated? 29 th September 2016 Agenda 1. About Iran 2. Implementation

More information

Implementation of Sanctions Relief for Iran

Implementation of Sanctions Relief for Iran January 18, 2016 clearygottlieb.com Implementation of Sanctions Relief for Iran On January 16, 2016, following a favorable report from the International Atomic Energy Agency, the P5+1 powers (the United

More information

Additional U.S. Sanctions with Respect to Iran Signed Into Law on January 2, 2013

Additional U.S. Sanctions with Respect to Iran Signed Into Law on January 2, 2013 Additional U.S. Sanctions with Respect to Iran Signed Into Law on January 2, 2013 January 7, 2013 Introduction On January 2, 2013, President Obama signed into law the Iran Freedom and Counter-Proliferation

More information

Selective OFAC Guideline Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA) on Implementation Day

Selective OFAC Guideline Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA) on Implementation Day Issued on January 16, 2016 Last Updated on December 15, 2016 Selective OFAC Guideline Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA) on Implementation

More information

TABLE OF CONTENTS PART I PETRONAS ECONOMIC SANCTIONS AND EXPORT CONTROL POLICY STATEMENT...4

TABLE OF CONTENTS PART I PETRONAS ECONOMIC SANCTIONS AND EXPORT CONTROL POLICY STATEMENT...4 1 TABLE OF CONTENTS PART I PETRONAS ECONOMIC SANCTIONS AND EXPORT CONTROL POLICY STATEMENT...4 PART II PETRONAS ECONOMIC SANCTIONS AND EXPORT CONTROL GUIDELINES..5-12 1. SCOPE OF APPLICATION.6 2. GUIDING

More information

Sanctions Compliance American Petroleum Institute March 27-28, 2017

Sanctions Compliance American Petroleum Institute March 27-28, 2017 Sanctions Compliance American Petroleum Institute March 27-28, 2017 Alan Kashdan International Trade Department Hughes Hubbard & Reed LLP Page 2 I. Introduction Introduction Sanctions are very much in

More information

THE UNITED STATES LIFTS SECONDARY SANCTIONS ON IRAN AND TAKES STEPS TO IMPLEMENT CERTAIN OTHER LIMITED SANCTIONS RELIEF

THE UNITED STATES LIFTS SECONDARY SANCTIONS ON IRAN AND TAKES STEPS TO IMPLEMENT CERTAIN OTHER LIMITED SANCTIONS RELIEF JANUARY 18, 2016 CIRCULAR NO. 04/16 TO MEMBERS OF THE ASSOCIATION Dear Member: THE UNITED STATES LIFTS SECONDARY SANCTIONS ON IRAN AND TAKES STEPS TO IMPLEMENT CERTAIN OTHER LIMITED SANCTIONS RELIEF January

More information

Iranian Nuclear Accord Reached, But Specific Implementation of Meaningful Sanctions Relief Will Not Be Immediate

Iranian Nuclear Accord Reached, But Specific Implementation of Meaningful Sanctions Relief Will Not Be Immediate July 16, 2015 Practice Group: International Trade Iranian Nuclear Accord Reached, But Specific Implementation of Meaningful Sanctions Relief Will Not Be Immediate By Daniel J. Gerkin and Jerome J. Zaucha

More information

Evolving U.S. Economic Sanctions and their Legal Implications Cuba, Iran, Russia and Burma

Evolving U.S. Economic Sanctions and their Legal Implications Cuba, Iran, Russia and Burma Evolving U.S. Economic Sanctions and their Legal Implications Cuba, Iran, Russia and Burma Christopher R. Wall July 2015 Pillsbury Winthrop Shaw Pittman LLP U.S. Economic Sanctions - Overview Administered

More information

(Non-legislative acts) REGULATIONS

(Non-legislative acts) REGULATIONS 7.8.2018 L 199 I/1 II (Non-legislative acts) REGULATIONS COMMISSION DELEGATED REGULATION (EU) 2018/1100 of 6 June 2018 amending the Annex to Council Regulation (EC) No 2271/96 protecting against the effects

More information

European Union Measures against Iran - Council Regulation 1263/ Frequently Asked Questions 29 January 2013

European Union Measures against Iran - Council Regulation 1263/ Frequently Asked Questions 29 January 2013 European Union Measures against Iran - Council Regulation 1263/2012 - Frequently Asked Questions 29 January 2013 Background 1. On 15 October 2012 the European Union Foreign Affairs Council agreed further

More information

Dancing Around Landmines: Hot Topics in U.S. and Canadian Sanctions. Momentum Events Webinar November 20, 2014

Dancing Around Landmines: Hot Topics in U.S. and Canadian Sanctions. Momentum Events Webinar November 20, 2014 Dancing Around Landmines: Hot Topics in U.S. and Canadian Sanctions Momentum Events Webinar November 20, 2014 Who we are Daniel Chapman Chief Compliance Officer and Counsel, Parker Drilling Company dan.chapman@parkerdrilling.com

More information

Managing Trade Compliance risk in Global Trade

Managing Trade Compliance risk in Global Trade Managing Trade Compliance risk in Global Trade TEID, Ethics and Reputation Society Hidiv Kasrı, Istanbul, February 20, 2018 Agenda for our discussion 1. What is Trade Compliance? 2. Understanding the risk!

More information

Same as It Ever Was: United States Re-imposes Sanctions on Iran

Same as It Ever Was: United States Re-imposes Sanctions on Iran ALERT MEMORANDUM Same as It Ever Was: United States Re-imposes Sanctions on Iran May 14, 2018 On May 8, 2018, President Trump announced that the United States will cease its participation in the Joint

More information

CLIENT UPDATE U.S. GOVERNMENT IMPOSES NEW SANCTIONS AGAINST IRAN

CLIENT UPDATE U.S. GOVERNMENT IMPOSES NEW SANCTIONS AGAINST IRAN CLIENT UPDATE U.S. GOVERNMENT IMPOSES NEW SANCTIONS AGAINST IRAN WASHINGTON DC Satish M. Kini smkini@debevoise.com NEW YORK Carl Micarelli cmicarelli@debevoise.com Eric P. Alpert epalpert@debevoise.com

More information

Senate Adopts New Sanctions Targeting Russia and Iran

Senate Adopts New Sanctions Targeting Russia and Iran Senate Adopts New Sanctions Targeting Russia and Iran June 16, 2017 On June 15, 2017, the United States Senate adopted S.722, incorporating the Countering Russian Influence in Europe and Eurasia Act of

More information

Maritime Law Association of Singapore U.S. Embargoes and Sanctions Knowing and Navigating the Changing Field in International and Cross-Border Deals

Maritime Law Association of Singapore U.S. Embargoes and Sanctions Knowing and Navigating the Changing Field in International and Cross-Border Deals Maritime Law Association of Singapore U.S. Embargoes and Sanctions Knowing and Navigating the Changing Field in International and Cross-Border Deals June 15, 2016 Ron Oleynik (202) 457-7183 ron.oleynik@hklaw.com

More information

U.S. and EU Sanctions on Iran and Russia For Le Cercle De la Compliance Beth Peters Lourdes Catrain Andrew Keller Aline Doussin.

U.S. and EU Sanctions on Iran and Russia For Le Cercle De la Compliance Beth Peters Lourdes Catrain Andrew Keller Aline Doussin. U.S. and EU Sanctions on Iran and Russia For Le Cercle De la Compliance Beth Peters Lourdes Catrain Andrew Keller Aline Doussin May 31, 2018 Agenda U.S. Sanctions Programs U.S. Sanctions: Considerations

More information

Client Alert: Doing Business with Iran after the US s Withdrawal from the Nuclear Deal

Client Alert: Doing Business with Iran after the US s Withdrawal from the Nuclear Deal 14 June 2018 Client Alert: Doing Business with Iran after the US s Withdrawal from the Nuclear Deal By Dr Kilian Bälz and Silke Noa Elrifai When US President Donald Trump announced in May 2018 that the

More information

Update on Trade Sanctions

Update on Trade Sanctions A n t i - B r i b e r y a n d I n t e r n a t i o n a l Tr a d e Update on Trade Sanctions Amber Road Complying with Export Controls 5 th. November 2015 Baker & McKenzie LLP is a member firm of Baker &

More information

ANNEX ANNEX. to the COMMISSION DELEGATED REGULATION (EU) /...

ANNEX ANNEX. to the COMMISSION DELEGATED REGULATION (EU) /... EUROPEAN COMMISSION Brussels, 6.6.2018 C(2018) 3572 final ANNEX ANNEX to the COMMISSION DELEGATED REGULATION (EU) /... amending the Annex to Council Regulation (EC) No 2271/96 of 22 November 1996 protecting

More information

David McLean Joint Deputy Head of the Office of Financial Sanctions Implementation

David McLean Joint Deputy Head of the Office of Financial Sanctions Implementation David McLean Joint Deputy Head of the Office of Financial Sanctions Implementation International Compliance Association 10 th Annual Conference April 2018 OFSI helps ensure financial sanctions are properly

More information

The Changing Sanctions Landscape and Law Enforcement s Perspective

The Changing Sanctions Landscape and Law Enforcement s Perspective The Changing Sanctions Landscape and Law Enforcement s Perspective Carlton M. Greene Presentation to ACAMS Northern California Chapter October 25, 2018 Crowell & Moring 1 Sanctions Basics The Treasury

More information

Private Placement Investors Association (PPiA) OFAC/Sanctions Due Diligence Questionnaire for Borrowers (Last Update: 7/22/15)

Private Placement Investors Association (PPiA) OFAC/Sanctions Due Diligence Questionnaire for Borrowers (Last Update: 7/22/15) Private Placement Investors Association (PPiA) OFAC/Sanctions Due Diligence Questionnaire for Borrowers (Last Update: 7/22/15) Involvement of Sanctioned Parties: 1) Is any Relevant Party or Relevant Person

More information

NOTICE TO EXPORTERS 2009/22. Iran Sanctions Frequently Asked Questions

NOTICE TO EXPORTERS 2009/22. Iran Sanctions Frequently Asked Questions NOTICE TO EXPORTERS 2009/22 Iran Sanctions Frequently Asked Questions Updating of previous Notices - PU 11a/07 Q&A - July 2007 and Notice to Exporters 2009/09-8 May 2009 This Notice replaces the previous

More information

Sanctions and End-Use Controls. Paul Whitfield-Jones Norton Rose Fulbright Julie Taylor Meggitt PLC

Sanctions and End-Use Controls. Paul Whitfield-Jones Norton Rose Fulbright Julie Taylor Meggitt PLC Sanctions and End-Use Controls Paul Whitfield-Jones Norton Rose Fulbright Julie Taylor Meggitt PLC Overview Sanctions in the UK Asset freezes Funds or assets belonging to or held, owned or controlled by

More information

Iran sanctions client briefing. Changes to EU and US sanctions Following the Joint Plan of Action

Iran sanctions client briefing. Changes to EU and US sanctions Following the Joint Plan of Action Iran sanctions client briefing Changes to EU and US sanctions Following the Joint Plan of Action 2 Iran Sanctions sanctions client briefing The Geneva Joint Plan of Action ( JPOA ), which was agreed between

More information

SUMMARY: The Department of the Treasury s Office of Foreign Assets Control (OFAC) is

SUMMARY: The Department of the Treasury s Office of Foreign Assets Control (OFAC) is This document is scheduled to be published in the Federal Register on 06/28/2018 and available online at https://federalregister.gov/d/2018-13939, and on FDsys.gov DEPARTMENT OF THE TREASURY Office of

More information

This Webcast Will Begin Shortly

This Webcast Will Begin Shortly This Webcast Will Begin Shortly If you have any technical problems with the Webcast or the streaming audio, please contact us via email at: webcast@acc.com Thank You! "Global Economic Sanctions: Cross-Border

More information

ECONOMIC SANCTIONS COMPLIANCE GUIDANCE MARCH 2016

ECONOMIC SANCTIONS COMPLIANCE GUIDANCE MARCH 2016 ECONOMIC SANCTIONS COMPLIANCE GUIDANCE MARCH 2016 Economic Sanctions - Compliance Guidance Introduction In recent years, sanctions legislation has become increasingly more complex and has had a significant

More information

Temporary Suspension of U.S. Sanctions Against Iran

Temporary Suspension of U.S. Sanctions Against Iran Temporary Suspension of U.S. Sanctions Against Iran January 21, 2014 Introduction The United States and the European Union have taken action to temporarily suspend certain economic sanctions against Iran

More information

Sanctions on Tehran: American Bets and Iranian Opportunities

Sanctions on Tehran: American Bets and Iranian Opportunities Sanctions on Tehran: American Bets and Iranian Opportunities Hussam Abu Hamed 2018-12-04 Introduction: In last May, US President Donald Trump decided to withdraw from a nuclear agreement with Iran, in

More information

Publication of Guidance Relating to the Provision of Certain Temporary Sanctions Relief,

Publication of Guidance Relating to the Provision of Certain Temporary Sanctions Relief, DEPARTMENT OF THE TREASURY Office of Foreign Assets Control Publication of Guidance Relating to the Provision of Certain Temporary Sanctions Relief, as Extended AGENCY: Office of Foreign Assets Control,

More information

THE UNITED STATES FORMALLY REIMPOSES SECONDARY SANCTIONS AGAINST IRAN

THE UNITED STATES FORMALLY REIMPOSES SECONDARY SANCTIONS AGAINST IRAN AUGUST 13, 2018 ALL INSUREDS AND BROKERS Dear Colleagues: THE UNITED STATES FORMALLY REIMPOSES SECONDARY SANCTIONS AGAINST IRAN Introduction On May 8, 2018, President Trump withdrew the United States from

More information

Presented by: Dennis Ansbro and Zoya Faynleyb ACAMS Greater Philadelphia Chapter December 10,2015

Presented by: Dennis Ansbro and Zoya Faynleyb ACAMS Greater Philadelphia Chapter December 10,2015 Presented by: Dennis Ansbro and Zoya Faynleyb ACAMS Greater Philadelphia Chapter December 10,2015 Sources and Types of Sanctions OFAC / HMT / EU / UN US Sanctions Key Concepts 2015 Recent Sanctions Developments

More information

Financial Sanctions Notice 26/03/2012

Financial Sanctions Notice 26/03/2012 Financial Sanctions Notice 26/03/2012 Iran (nuclear proliferation) Council Regulation (EU) No 267/2012 This notice is issued in respect of the restrictive measures directed by the Council of the European

More information

Congress Reaches Agreement on New Sanctions against Russia, North Korea, and Iran

Congress Reaches Agreement on New Sanctions against Russia, North Korea, and Iran Congress Reaches Agreement on New Sanctions against Russia, North Korea, and Iran July 27, 2017 On July 25, 2017, the United States House adopted H.R. 3364, the Countering America s Adversaries Through

More information

U.S. Economic Sanctions

U.S. Economic Sanctions U.S. Economic Sanctions Nicholas F. Coward, Partner Terence Gilroy, Partner October 31, 2018 Austrian Chamber of Commerce Agenda 1 U.S. Sanctions Overview 3 2 Iran 9 3 Russia 12 4 Questions 15 U.S. Sanctions

More information

SANCTIONS & HIGH RISK QUESTIONNAIRE

SANCTIONS & HIGH RISK QUESTIONNAIRE Date of Completion D D M M Y Y Y Y CIF Number Customer Name a. Please provide your current list of top 5 suppliers and clients: Sr. No. Name Country 1 2 3 4 5 1 2 3 4 5 / b. Do you trade in products or

More information

Off to Iran? What you should know before you enter the market. International Business

Off to Iran? What you should know before you enter the market. International Business Off to Iran? What you should know before you enter the market 2016 International Business Lifted trade barriers, great prospects: Iran is where it s at The country between the Caspian Sea and the Persian

More information

Export Compliance: Sanctions, Embargos, Denied Parties

Export Compliance: Sanctions, Embargos, Denied Parties Export Compliance: Sanctions, Embargos, Denied Parties Lizbeth C. Rodriguez-Johnson Holland & Hart, LLP 555 17 th Street, Denver CO 303-295-8399 lrodriguez@hollandhart.com October 16, 2017 Copyright Holland

More information

Sanctions & Embargoes. Do you know how they work and how they may impact your business?

Sanctions & Embargoes. Do you know how they work and how they may impact your business? Sanctions & Embargoes Do you know how they work and how they may impact your business? As an Agribusiness customer it s important to understand your obligations in relation to domestic and international

More information

International Sanctions: where are we now? TOM CUMMINS 13 JUNE 2017

International Sanctions: where are we now? TOM CUMMINS 13 JUNE 2017 International Sanctions: where are we now? TOM CUMMINS 13 JUNE 2017 Introduction TOM CUMMINS Tom Cummins Partner T +44 (0)20 7859 1051 M +44 (0)7900 890 679 tom.cummins@ashurst.com Partner in Ashurst s

More information

AN OVERVIEW OF U.S. EXPORT CONTROLS & ECONOMIC SANCTIONS

AN OVERVIEW OF U.S. EXPORT CONTROLS & ECONOMIC SANCTIONS AN OVERVIEW OF U.S. EXPORT CONTROLS & ECONOMIC SANCTIONS Christine Lee Senior Director, Associate General Counsel United Technologies Corp. Yoshihide Ito Partner Morgan, Lewis & Bockius LLP 1 EXPORT CONTROL

More information

US Sanctions on Iran: 2012 Year in Review

US Sanctions on Iran: 2012 Year in Review February 25, 2013. I. Introduction The United States first imposed sanctions against Iran in 1979, and established the current Iran sanctions framework in the mid-1990s with the passage of the Iran and

More information

EXECUTIVE ORDER REIMPOSING CERTAIN SANCTIONS WITH RESPECT TO IRAN. By the authority vested in me as President by the

EXECUTIVE ORDER REIMPOSING CERTAIN SANCTIONS WITH RESPECT TO IRAN. By the authority vested in me as President by the EXECUTIVE ORDER - - - - - - - REIMPOSING CERTAIN SANCTIONS WITH RESPECT TO IRAN By the authority vested in me as President by the Constitution and the laws of the United States of America, including the

More information

Group Sanctions Policy

Group Sanctions Policy Group Sanctions Policy 1. Purpose This Policy provides instruction with regards to the treatment of, and compliance with, sanctions or restrictive measures imposed on countries, territories, entities,

More information

International Trade Alert

International Trade Alert International Trade Alert Iran Sanctions Are Here Breaking Down What This Means For Business November 26, 2018 Key Points As of November 5, 2018, the United States concluded the second of two wind-down

More information

Additional U.S. Sanctions with Respect to Iran Signed Into Law on August 10, 2012: The Iran Threat Reduction and Syria Human Rights Act of 2012.

Additional U.S. Sanctions with Respect to Iran Signed Into Law on August 10, 2012: The Iran Threat Reduction and Syria Human Rights Act of 2012. Additional U.S. Sanctions with Respect to Iran Signed Into Law on August 10, 2012: The Iran Threat Reduction and Syria Human Rights Act of 2012. August 15, 2012 Introduction On August 1, 2012, the U.S.

More information

A copy of Regulation 2018/1100 attaching the new Annex and a Guidance Note issued by the European Commission are attached.

A copy of Regulation 2018/1100 attaching the new Annex and a Guidance Note issued by the European Commission are attached. August 2018 To the Members Dear Sirs, European Union Regulation 2271/96 (Blocking Regulation) Background Circular L.315 issued in May 2018 outlined the potential repercussions for shipowners and insurers

More information

FREEHILL HOGAN& MAHAR LLP

FREEHILL HOGAN& MAHAR LLP FREEHILL HOGAN& MAHAR LLP CLIENT ALERT: THE U.S. RATCHETS UP SANCTIONS ON IRAN WITH BACK-TO-BACK ISSUANCE OF PRESIDENT OBAMA S EXECUTIVE ORDER AUTHORIZING ADDITIONAL SANCTIONS WITH RESPECT TO IRAN AND

More information

IRAN - IMPACT OF SANCTIONS OVERVIEW OF LEGISLATION AND REGULATIONS UPDATED 9th NOVEMBER 2010

IRAN - IMPACT OF SANCTIONS OVERVIEW OF LEGISLATION AND REGULATIONS UPDATED 9th NOVEMBER 2010 IRAN - IMPACT OF SANCTIONS OVERVIEW OF LEGISLATION AND REGULATIONS UPDATED 9th NOVEMBER 2010 There follows an overview of the current legislation and regulations currently affecting, or with the potential

More information

Responding Properly To OFAC Obligations

Responding Properly To OFAC Obligations Responding Properly To OFAC Obligations The web seminar has not yet started: A sound check will be performed 5 minutes before the start time. COPYRIGHT NOTICE USE OF WEBEX LOGIN/PASSWORD FOR ACAMS WEB

More information

International Trade Alert

International Trade Alert International Trade Alert Enactment of Comprehensive Iran Sanctions Act Expands Extraterritorial Reach of the U.S. Embargo on Iran June 29, 2010 OVERVIEW On June 24, 2010, the U.S. House and Senate voted

More information

(Non-legislative acts) REGULATIONS

(Non-legislative acts) REGULATIONS 24.1.2012 Official Journal of the European Union L 19/1 II (Non-legislative acts) REGULATIONS COUNCIL IMPLEMENTING REGULATION (EU) No 54/2012 of 23 January 2012 implementing Regulation (EU) No 961/2010

More information

Antitrust and Competition

Antitrust and Competition JULY In this issue: Antitrust and Competition... 1 International Trade, Customs and External Relations... 2 Energy and Renewables... 2 Telecommunications, Media and Technology... 3 Privacy, Data Protection

More information

AND IRAN SO FAR AWAY IRANIAN SANCTIONS LAWS & DUE DILIGENCE Presented on June 5, 2013 Piraeus Marine Club

AND IRAN SO FAR AWAY IRANIAN SANCTIONS LAWS & DUE DILIGENCE Presented on June 5, 2013 Piraeus Marine Club AND IRAN SO FAR AWAY IRANIAN SANCTIONS LAWS & DUE DILIGENCE Presented on June 5, 2013 Piraeus Marine Club George J. Tsimis Senior Vice President Head of Claims & General Counsel Shipowners Claims Bureau,

More information

Sanctions. Sanctions Spotlight. Kerri-Ann Bent

Sanctions. Sanctions Spotlight. Kerri-Ann Bent Sanctions Sanctions Spotlight Kerri-Ann Bent Sanctions Overview Sanctions are restrictions on Economic and Business activity related to certain countries, individuals, Entities, industries or types of

More information

With many multi-million. Insights. Peace of mind. Negotiating the sanctions regulatory maze: Key jurisdictions to consider

With many multi-million. Insights. Peace of mind. Negotiating the sanctions regulatory maze: Key jurisdictions to consider Peace of mind Negotiating the sanctions regulatory maze: Key jurisdictions to consider Insights With many multi-million dollar lawsuites plaguing even the biggest global companies, understanding the regulatory

More information

Back to the Future: The Return of U.S. Sanctions, their Economic Impact, and Iran s Response

Back to the Future: The Return of U.S. Sanctions, their Economic Impact, and Iran s Response Back to the Future: The Return of U.S. Sanctions, their Economic Impact, and Iran s Response Contents 1. What are economic sanctions? Success / failure factors 2. History of economic sanctions against

More information

US Sanctions Summary (updated September 2018)

US Sanctions Summary (updated September 2018) US Sanctions Summary (updated September 2018) The US Government maintains a variety of economic sanctions, ranging from comprehensive to more limited restrictions. Some sanctions programs are based on

More information