Sanctions Experts Release Legal Manual on State of US Sanctions on Iran Following Nuclear Agreement
Washington, DC – Iran sanctions experts, Babak Hoghooghi, Benjamin H. Flowe, Jr., and Dan Fisher-Owens recently released a legal practice guide devoted to the topic of US trade sanctions against Iran entitled, State of US Sanctions on Iran in the Aftermath of the P5+1 Agreement: Permissible Scope of Commercial Activities by US Persons. This legal manual addresses numerous topics which may arise when transacting with Iran.
The document notes that if the nuclear agreement passes congressional consent and is implemented this September, US sanctions on Iran will be eased in the following sectors:
- Financial and banking
- Oil, gas and petrochemical
- Shipping, shipbuilding, and port operations
- Automotive
- Trade in gold and other precious metals
- Trade in graphite, raw or semi-finished metals, coal and software for integrating industrial processes
- Insurance for the foregoing activities otherwise permitted under the JCPOA.
However, the legal manual also states that US Persons will continue to be prohibited from engaging in most commercial activities in or relating to Iran, including:
- Dealings with the Government of Iran or SDNs
- Exporting goods or services to Iran
- Importing Iranian-origin goods or services to the U.S
- Other dealings in Iranian-origin goods or services
- New investments in Iran
- Facilitating any of the foregoing transactions undertaken by non-U.S. Persons
- Entering into any executory or other contracts concerning any of the foregoing transactions to be undertaken in the future.
US Persons may continue to legally export food, medicine, basic medical supplies, and services, software and hardware incident to personal communications to Iran under existing OFAC general licenses, and otherwise engage in any activities authorized by OFAC.
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