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US Leaves JCPOA Intact But Is Still Ratcheting Up Sanctions Against Iran

When the United States lifted its nuclear-related sanctions as part of its Implementation of the Joint Comprehensive Plan of Action (JCPOA) in January 2016, it left in place several other sanctions mechanisms that could be implemented against Iran. On February 3, following Iran’s tests of certain ballistic missiles, the United States designated twenty-five (25) additional individuals and entities as Specially Designated…

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Snapback: The More You Know, the Better Prepared You Can Be

The possibility of a snapback of the nuclear sanctions against Iran has created uncertainty since before Implementation Day of the Joint Comprehensive Plan of Action (JCPOA) in January 2016. Now as we near the one year anniversary of the implementation of the JCPOA, uncertainty seems to loom larger as we also face a new US President and Administration. By Susan…

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The Wait is Almost Over: What Will Happen with US Sanctions under the Incoming Trump Administration

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

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Do US Changes Regarding Cuba Create Opportunities for Your Business?

Given that the EU has adopted blocking legislation that makes it illegal for persons resident in the EU to refuse business opportunities based on the US embargo against Cuba, some might wonder why I am writing about the US embargo of Cuba. Well, for a change, I am writing about possible opportunities to engage US business partners in your Cuban…

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Despite Iran sanctions relief, limitations remain on non- US companies owned or controlled by US persons

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…

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Be wary of facilitation by US persons following JCPOA implementation

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…

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