The European Commission has started the process by which it
would add US sanctions measures on Iran to the so-called Blocking
Regulation (formerly Regulation 2271/96). This is in direct
response to the US President's withdrawal of his waiver
relating to the JCPOA. The effect of the withdrawal was to
reintroduce US sanctions that were in force prior to the JCPOA. US
sanctions on Iran not only impact US companies and persons, but
can, in certain circumstances be applied to non-US persons. The
most important extension of US jurisdiction relates to non-US
subsidiaries of US companies. However, the US also has powers to
place so-called "secondary sanctions" on non-US persons.
These can be placed on any person (i.e., including non-US persons
acting wholly outside US jurisdiction) engaging in certain
"sanctionable activities," as defined by the relevant US
laws and regulations. These "sanctionable activities" are
detailed in OFAC's recent FAQ document available here. The US
