The Prohibitions
On May 8, 2018, the United States withdrew from the Joint
Comprehensive Plan of Action and reimposed all pre-JCPOA sanctions
against Iran. We provide a detailed discussion of the reimposition
in our article linked here (and linked here is our prediction, a year earlier,
that it would happen). After a prescribed wind-down period, all
U.S. sanctions on Iran are now in force. Effectively, U.S.
sanctions on Iran now return to their pre-2016 levels, including
secondary sanctions on non-U.S. companies transacting with the
Government of Iran and many of Iran's industries and financial
institutions.
The Business That May Continue
While the reimposition of economic sanctions on Iran
significantly restricts what business can be done with the country,
certain transactions will not raise the risk of sanctions liability
for non-U.S. persons. Generally, if a transaction meets the
following criteria, it is not likely to expose a non-U.S. company
to sanctions
