THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 73, October 2018

Back to the past with Iran: peering through the cloud of section 1246

The resurrection of US secondary sanctions following the country’s JCPOA withdrawal will likely impact the global insurance market. David J. Brummond reviews the key provisions of section 1246 of..

The resurrection of US secondary sanctions following the country’s JCPOA withdrawal will likely impact the global insurance market. David J. Brummond reviews the key provisions of section 1246 of the Iran Freedom and Counterproliferation Act of 2012 and suggests possible ways insurers may be able to mitigate their impact.   The withdrawal of the United States from the Joint Comprehensive Plan of Action (‘JCPOA’)1 with Iran resurrects ‘secondary sanctions’ on non-US persons engaging in certain conduct and activities with Iran. While some of these secondary sanctions were activated on 6 August 2018, most will become operative on 4 November 2018.2 One...



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