July 2018

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On May 8, 2018, President Donald Trump announced that the U.S. will withdraw from the Iran nuclear deal, formally known as the Joint Comprehensive Plan of Action (JCPOA), and reimpose the strict economic sanctions program that was in place prior to the landmark 2015 agreement.  Based on the guidance issued by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), the reimposed sanctions will impact businesses outside of the U.S. that engage in  business with or in Iran, particularly those who do so while also seeking to maintain or establish a U.S. presence or dealings with U.S. companies. The “secondary sanctions” control who those foreign entities can do business with and restrict how foreign entities can utilize the U.S. financial system.  Foreign persons and businesses can also be held liable for causing U.S. persons to violate sanctions regulations. (more…)