Introduction to Sanctions
Wednesday, 30 May 2018
(June 26th, 4PM - 7PM)
The US has signaled its intention to withdraw from JCPOA and reinstate all US sanctions in force against Iran prior to January 2016, including the full suite of secondary sanctions applicable to non-US persons. Politics aside, these developments have potentially profound implications for anyone who has engaged Iran in trade activities or investment under the JCPOA and anyone who is only now considering to enter into an Iranian transaction. What has transpired and what we should expect?
A guide to Iranian Sanctions: Implications of the US Withdrawal on Post-JCPOA Legal Framework
- Introduction (brief discussion on the Post-JCPOA Legal Framework of sanctions and main body of measures remained in force, updates on the decision of U.S. administration and efforts made by other counter-parties to support the Iran Deal);
- Effects of US Withdrawal from the JCPOA (addressing the U.S. Sanctions which are to be Re-instated and respective deadlines, procedural framework, winding down and getting paid under existing Iranian contracts, guidance concerning payments connected with wind-down activities, status of OFAC licenses upon withdrawal, etc.)
- Effects on U.S. and Non-US Persons (elaborating the definition and scope of a U.S. person under related laws and regulations, brief overview on the mechanism under which U.S. secondary sanctions operate, consequences for Violating US Sanctions by Non-US Persons, companies affected by the wind down obligation (Potential Options for Wind Down), and companies not directly affected by the wind down obligation);
- Practical issues when dealing with Iranian counter parties (discussing issues related to dealing with persons appearing on the SDN List, risks and costs of compliance, contractual remedies, conducting a proper KYC, etc.);
- Q&A dialogue.