Sanctions alert: limited easing of certain Iran sanctions

On 20 January 2014, as part of the Joint Plan of Action, the US and the EU implemented ‘limited, targeted, temporary and reversible’ relief from certain sanctions measures in return for Iran’s agreement to commence the winding down of certain aspects of its nuclear programme. This limited easing is valid for a six-month period only, until 20 July 2014, and if there is no comprehensive agreement with Iran by that time, those EU and US sanctions that have been temporarily suspended will come back into force. Outlined below are the key aspects of this development and its impact on US companies (and their non-US subsidiaries) as well as on foreign companies that are not ultimately owned or controlled by US persons/entities…

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