THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 78, April 2019

Contours of change: US Iran sanctions – from Helms-Burton to the SPV

Mario Mancuso and Anthony Rapa explore the history of US secondary sanctions in the Iran context – and how that should impact on companies’ compliance strategies.

Mario Mancuso and Anthony Rapa explore the history of US secondary sanctions in the Iran context – and how that should impact on companies’ compliance strategies.   5November 2018 marked a key turning point for US economic sanctions, as the United States fully implemented its re-imposition of ‘nuclear-related’ sanctions against Iran pursuant to its withdrawal from the Joint Comprehensive Plan of Action (‘JCPOA’) earlier that year. Much of the impact of the re-imposed sanctions, as has been well noted by now, will be felt outside the United States. Notably, the new sanctions are facing vigorous opposition from Europe in particular,...

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