Additional Iran sanctions legislation

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Congress is working on new Iran sanctions legislation that would further target the activities of non-US companies with Iran, even when the activity has no US nexus. Specifically, the House of Representatives already passed H.R. 850, the Nuclear Iran Prevention Act of 2013, by a vote of 400–20 on 31 July 2013, which would impose new sanctions on non-US companies doing business with Iran. H.R. 850 has been referred to the Senate Committee on Banking, Housing, and Urban Affairs for consideration.

This new legislation would primarily impact non-US companies (even those with no US operations or any other US nexus) because it would expand the types of sanctionable activities that could expose foreign companies to the imposition of restrictive measures under US law. Certain measures cut across all industry sectors. Federal contractors would be adversely affected because the legislation would require a broader certification regarding Iran-related activities of any affiliates globally and not just the activities of the US contracting entity or its subsidiaries…

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