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. and EU trade restrictions on doing business in Iran diverged markedly – a period marked by large enforcement actions by the United States against a number of EU banks for Iran-related activities. Click here for more
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