U.S. sanctions involving Iran have been a forefront topic recently, with some continuing confusion as to the current state of the sanctions' provisions for most U.S. businesses. On January 20, 2014, the P5 + 1 Agreement (or "Interim Deal") took effect reflecting the six-month interim sanctions deal with Iran that was negotiated in November by a U.S.-led coalition of states. For now, however, the U.S. Government has emphasized that the P5 + 1 Agreement has little impact on trade restrictions currently limiting U.S. trade and investment with Iran.
Published Joint Guidance Confirms U.S. Sanctions Currently Remain -
To clarify this position, the U.S. Departments of State and Treasury released joint guidance on January 20, noting that, but for extremely limited exceptions, no sanctions relief would impact U.S. businesses or foreign companies controlled by U.S. persons. That is, U.S. economic sanctions remain in place, as well as subsidiary liability, Securities and Exchange Commission (SEC) reporting requirements, and all "blocks" on persons and entities on the Specially Designated Nationals (SDN) list. Importantly, the Obama Administration fully intends to continue to enforce Iranian sanctions during the interim period. Indeed, the relief has been described as "limited, targeted and reversible."
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