The UK, France and Germany (the European signatories to the Joint Collective Plan of Action (“JCPOA”) nuclear deal with Iran in 2015, referred to as the “E3”) have decided to retain certain sanctions previously imposed upon Iran. The press release published by the E3 announcing this decision is available here. The JCPOA was agreed in 2015 between the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom and the United States, with the EU’s…
Just before the holidays, President Biden signed two bills passed in the final days of the last Congress that contain a number of provisions with implications for sanctions, export controls, and supply chain restrictions: On December 23, 2022, President Biden signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2023 (P.L. 117-263). The measure includes a number of provisions relating to US export controls, sanctions, and related subjects, including additional sanctions targeting…
Effective October 28, 2022, Canada implemented additional sanctions against Iran due to its “ongoing gross and systematic human rights violations and continued actions to destabilize regional peace and security.” An additional four individuals and two entities have been listed under Schedule 1 of the Special Economic Measures (Iran) Regulations (the “Regulations”). Generally speaking, listing under Schedule 1 of the Regulations imposes a dealings prohibition, effectively an asset freeze, against the listed person. Any person in…
On September 23, 2022, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued Iran General License D-2 (“GL D-2”), which amends and replaces the former Iran General License D-1 (“GL D-1”), and published three related Frequently Asked Questions (“FAQs”). GL D-2 authorizes a more expansive set of internet communication-related activities, including cloud-based software and services, that are otherwise prohibited under the Iranian Transactions and Sanctions Regulations (“ITSR”). According to the accompanying…