On May 8, 2018, United States ("US") President Trump announced his decision to withdraw the US' participation in the Joint Comprehensive Plan of Action ("JCPOA"), and to begin re-instating the US nuclear-related sanctions, following a wind-down period. According to the Presidents statement:
The full White House fact sheet can be found here.
The US will begin the process of implementing 90-day and 180-day wind-down periods for activities involving Iran (i.e. steel, aluminium and coal 90 days, financial transactions 90 days and petrochemical transactions 180 days). At the end of the 90-day and 180-day wind-down periods, the applicable sanctions will come back into full effect.
The Office of Foreign Assets Control posted additional frequently asked questions (FAQs) on its website in order to provide additional guidance on the sanctions that are to be re-imposed and the relevant wind-down periods.
Challenges when considering doing business in Iran
Should you consider doing business in Iran, please consider the following:
Despite the less than ideal restrictions and considerations described above, doing business with Iran is possible from an EU perspective for the moment still. However, should the US Iran sanctions regime be fully re-imposed this may obstruct you from pursuing Iran related transactions, despite being allowed to enter into the contemplated transactions under the EU Iran sanctions regime. Therefore, carefully determine your risk and whether you have ensured the appropriate and adequate levels of compliance.
Contact Wladimiroff Advocaten
Wladimiroff Advocaten advises many companies on the US and EU Iran sanctions regimes. Should you have any questions related hereto, please feel free to contact us at :+31(0)70 416 6616 or send an email to firstname.lastname@example.org or email@example.com