The U.S. withdrawal from the Iran nuclear proliferation deal known as the Joint Comprehensive Plan of Action (“JCPOA”) and the resulting reimposition of sanctions against Iran, especially secondary sanctions, i.e., sanctions against non-U.S. persons conducting Iranian business, poses serious problems for EU and other international companies.

Since the U.S. withdrawal, the EU has made it very clear that it is committed to the JCPOA and has reacted to the U.S. reimposition of secondary sanctions by making compliance with certain identified U.S. sanctions laws by EU companies and EU nationals illegal through the introduction of an amendment to the EU Blocking Regulation. This amendment came into force on August 7, 2018 in the form of (1) Commission Delegated Regulation (EU) 2018/1100 and (2) Commission Implementing Regulation (EU) 2018/1101.