The January 20, 2014 temporary suspension announced by U.S. officials of some of the more recent sanctions targeting business by non-U.S. companies and persons with Iran leaves in place sanctions that apply to U.S. persons and their owned or controlled non-U.S. affiliates, as well as sanctions targeting many important sectors of Iran’s economy. Accordingly, for U.S. companies and their owned or controlled non-U.S. affiliates, the Iran sanctions landscape has not changed. Non-U.S. affiliated companies that are now contemplating activities in Iran should first assess whether such activities could run afoul of the many remaining Iran sanctions, as well as the inherent risks in engaging in business pursuant to a change in sanctions that is “temporary” and may be revoked at any time.
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