On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more
How should we approach competing sanctions risks? Among the numerous regulatory compliance risks faced by financial institutions, economic and trade sanctions risks commonly receive a great deal of attention....more
• As of November 5, 2018, the United States concluded the second of two wind-down periods for re-imposition of U.S. sanctions on Iran following the May 8, 2018, announcement that the United States would cease participation in...more
As of November 5, 2018, US secondary sanctions against Iran are back in force, and more than 700 Iranian individuals and entities have been re-added or newly added to the US Specially Designated Nationals and Blocked Persons...more
On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more