Sanctions in Transition – How the Joint Comprehensive Plan of Action has Liberalized U.S. and EU Sanctions Against Iran and What Challenges Remain

On April 13, Harry Clark, partner in Orrick's Washington, D.C. office and Elizabeth Zane, associate in Orrick's Washington, D.C. office, provided updates on U.S. and EU sanctions against Iran in a live webinar.

The July 2015 Joint Comprehensive Plan of Action (JCPOA), as implemented, includes landmark U.S. and EU commitments to liberalize sanctions. However, there are important limitations on those commitments, and much will depend on continuing implementation steps by governments on both sides of the Atlantic. This event unraveled the complexities of where sanctions stand today and how they could change.

Topics covered included:

• Broad EU sanctions relief
• Broad termination and suspension of U.S. “secondary” sanctions measures applicable to non-U.S. companies outside the United States
• Substantial, but limited, U.S. sanctions relief for non-U.S. subsidiaries of U.S. companies (“General License H”)
• Incremental relaxation of the U.S. embargo on most dealings with Iran by “U.S. persons”

A recording of the presentation can be viewed above. Should you have any issues accessing the recording or if you would like a copy of the slides, please contact Stephanie Heyworth at [email protected].