The Countering America’s Adversaries Through Sanctions Act (the CAATS Act) of August 2, 2017 impacts sanctions related to Russia, Iran and North Korea. Key among the changes is that it takes discretion out of the hands of the U.S. President to lift or change certain existing sanctions, particularly the sectoral sanctions imposed against Russia.
Based on comments made by President-Elect Trump during his campaign, we have some indications about the positions his administration may take regarding certain US sanctions programs. By Susan Kovarovics, 11 November 2016
In the wake of eased sanctions against Iran, companies operating in Europe may wish to take advantage of new opportunities involving Iran, including having employees travel to Iran to explore such opportunities. However, having employees engage in such travel gives rise to considerations under the US Visa Waiver Program should the employee subsequently travel to the United States. By Megan…
Much attention has been paid as of late to the sanctions relief granted to Iran arising out of the Joint Comprehensive Plan of Action (JCPOA) among the United States and its partners in the P5 + 1 (China, France, Germany, Russia, and the United Kingdom). Although US sanctions relief remains limited, General License H authorizes non-US subsidiaries of US companies…
There is growing frustration in Iran and Europe about the slow pace of reconnecting Tehran to the global financial system. This even led to a recent joint statement by the P5 +1 nations that negotiated the JCPOA explicitly underlining that they will not “stand in the way of permitted business activity with Iran, and will not stand in the way…
The changes made by the United States to its sanctions against Iran on Implementation Day resulted in the lifting of most of the secondary sanctions imposed on non-US parties engaging in transactions with Iran or designated parties associated with Iran. Implementation Day also yielded a general license that authorizes transactions by non-US subsidiaries of US persons involving Iran and the…
Among the provisions of the Joint Comprehensive Plan of Action (JCPOA), one that has been touted by the United States as a key provision and which received much attention is the “snapback” provision. Set forth in Article 37 of the JCPOA, the snapback provision is part of the dispute resolution mechanism set forth in the document. It provides the basis…
