On May 8, 2018, President Trump announced that the United States would cease implementing the Joint Comprehensive Plan of Action (“JCPOA”), triggering a re-imposition of certain previously suspended sanctions on Iran. Much of the immediate impact of this change in U.S. policy will be on non-U.S. companies that will now need to be concerned with the re-imposition of secondary sanctions applicable to non-U.S. persons. Significantly, this change in U.S. policy returns U.S. and non-U.S. companies doing business globally back to the challenging compliance environment beginning in 2010 – after U.S.

In light of the anticipated lifting of most international sanctions against Iran in 2016, this Cleary Gottlieb Alert Memo sets forth possible avenues for securing protection under Iran’s investment treaties. Given the specificities of these regimes, a detailed analysis of each investor’s individual situation is strongly recommended. Read more.