United States Attempts UN Sanctions Snapback on Iran

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Summary -

After the United Nations Security Council (“UNSC”) declined to extend a conventional arms embargo on Iran, the United States sought to unilaterally trigger a UN sanctions “snapback” provision and issued a new Executive Order to restrict arms trade with Iran by non-U.S. persons. Neither the snapback of UN sanctions, if effective, nor the new EO should substantially change financial institutions’ compliance obligations.

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