Updated EU Blocking Statute Targeting Reinstated US Iran Sanctions Enters Into Force

Following President Trump's decision to withdraw from the Joint Comprehensive Plan of Action ("JCPOA") and to reinstate US sanctions against Iran, the European Commission ("Commission") published on June 6, 2018 a proposal for a delegated regulation, updating Council Regulation 2271/96, the so-called "Blocking Statute," to counter the extraterritorial effects of these reinstated sanctions. (See our May 24 Legal Update.)

In the absence of any objection from the European Parliament and the Council of the European Union, Commission Delegated Regulation (EU) 2018/1100 has been adopted and entered into force on August 7, 2018, i.e., at the same time the first batch of US sanctions are reinstated.¹