As of November 5, 2018, all of the US sanctions that were lifted or waived in connection with the Joint Comprehensive Plan of Action (JCPOA), the 2016 nuclear deal among the United States and its allies and Iran, have been re-imposed and are in full effect. As a result, non-US companies can be subject to significant sanctions, and even blocked from accessing US markets, if they engage in certain activities involving Iran or certain Iranian persons (as well as entities owned 50 percent or more by such persons), related to key sectors, such as energy; banking; shipping and shipbuilding; and insurance, reinsurance, and underwriting.

Norton Rose Fulbright has prepared an analysis of the key provisions, and some practical implications, of the re-imposed sanctions.

The Legal Update was written by:

Stephen M. McNabb, a partner in the Norton Rose Fulbright Washington, DC office

David Harris, a partner in the Norton Rose Fulbright London office

Jeffrey Cottle, a partner in the Norton Rose Fulbright London and Washington, DC offices

Katie McDougall, Of Counsel in the Norton Rose Fulbright London office

Kimberly Hope Caine, a senior counsel in the Norton Rose Fulbright Washington, DC office

Edward Malcolm, an associate in the Norton Rose Fulbright London office

In a somewhat related development, on October 11, 2018, the Financial Crimes Enforcement Network (FinCEN), the US anti-money laundering agency, issued an “Advisory on the Iranian Regime’s Illicit and Malign Activities and Attempts to Exploit the Financial System” providing information on the “threats the Iranian regime poses to the U.S. financial system” and warned that the full re-imposition of the economic sanctions will likely lead to more efforts by the Iranian regime to evade them.