On April 22, 2019, the Trump Administration announced that the US government will not reissue the significant reduction exceptions (“SREs”) that have allowed energy companies in China, India, Italy, Greece, Japan, South Korea, Taiwan, and Turkey to purchase Iranian oil without being subject to relevant US sanctions. The current waivers will expire on May 2, 2019.
On April 17, 2019, the Trump Administration announced several decisions that mark a significant shift in US policy toward Cuba, most notably by declaring that the United States will no longer suspend Title III of the LIBERTAD Act of 1996, which is also known as the Helms-Burton Act.
On April 8, 2019, the Trump administration escalated pressure on Iran by announcing its plan to designate the Islamic Revolutionary Guard Corps (“IRGC”) as a Foreign Terrorist Organization (“FTO”) under Section 219 of the Immigration and Nationality Act. The designation marks the first time the United States has branded a foreign government military entity a terrorist group. In retaliation, Iran designated US forces in the Middle East as a terrorist group.
US trade sanctions and export controls targeting Iran have attracted increasing attention from Chinese companies doing business in Iran or with Iran counterparties. This client alert aims to provide a high-level overview on US trade sanctions and export controls targeting Iran, their implications (particularly in terms of their extraterritorial application), and the potential penalties that can be imposed on companies and their executives and employees in the event of violations.