On 29th August, law firm HFW issued a briefing outlining the position of the re-imposed US sanctions on Iran and the effect of the EU Blocking regulation, which sets out to mitigate the effects of the re-imposed sanctions. It details the US sanctions being re-imposed w.e.f. from 6th August and 4th November. It examines the 4 key aspects of the Blocking Regulation. The article makes several recommendations for those who might be affected, including maintaining careful records to document the reasons for any decision to stop work or cease business operations in Iran on the basis of the EU operator’s own assessment of the economic situation, as opposed to the US extraterritorial sanctions which are the target of the EU Blocking Regulation.
http://www.hfw.com/Iran-Sanctions-Steering-a-course-through-difficult-waters-August-2018