On May 10th, Wilmer Hale produced a very useful briefing that includes a summary of the sanctions situation prior to the Trump announcement, what he announced and what it all means.  It also poses what it calls strategic questions for the US, Iran, EU and others, and comments on compliance questions for the private sector.  It concludes that the US withdrawal from the JCPOA greatly complicates diplomatic and commercial activities surrounding Iran.  It will likely enhance tensions not only between Iran and the US, but also between the US and the EU, and between the US and countries like Russia and China. Having played a significant hand against the JCPOA, the US will have to determine whether it will double down in adopting an aggressive enforcement posture, including by imposing secondary sanctions on foreign entities for doing business in Iran. The wind-down periods present an important time for US and non-US companies to assess their exposure to US sanctions against Iran and to prepare for the re-imposition of pre-JCPOA prohibitions.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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