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ARTICLE · 20 JANUARY 2016

Six Crucial Points About Iran Sanctions Liberalization

Orrick
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The U.S. government has, by and large, left in place its embargo generally forbidding U.S. companies, citizens and residents, and others in the United States to engage in Iran-related activity.

United StatesInternational Law
Harry Clark
Harry Clark
Colin Graham
Colin Graham
W. Clark McFadden II
W. Clark McFadden II
Elizabeth Zane
Elizabeth Zane
Evgeniya Shakina
Evgeniya Shakina
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Crucial Points

  1. The U.S. government has, by and large, left in place its embargo generally forbidding U.S. companies, citizens and residents, and others in the United States to engage in Iran-related activity.
  2. European Union authorities, on the other hand, have rescinded most EU economic sanctions relating to Iran.
  3. The U.S. government has neutralized most so-called "secondary sanctions" measures that have provided for sanctions against third country companies that engage in specified types of activities relating to Iran.  
  4. The U.S. government has also, for the most part, eliminated the embargo's application to non-U.S. subsidiaries of U.S. companies acting abroad.  Furthermore, the U.S. government has, in limited respects, authorized U.S. parent companies to permit and, to some limited extent, enable their non-U.S. subsidiaries to engage in Iran-related activity.  But U.S. parent companies will need to be careful to avoid support for their non-U.S.

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