Is Iran Open for Business? Most “Secondary Sanctions” Lifted but the Situation Remains Largely Unchanged for U.S. Persons
In a move that opens the door for non-U.S. companies to engage in transactions with or in Iran, on January 16, 2016, the U.S. scaled back economic sanctions against Iran. As a result:
- Non-U.S. persons, including non-U.S. entities, may now, with limited exceptions discussed below, do business with or in Iran without risk of sanction.
- Foreign subsidiaries of a U.S. parent are also allowed, with some exceptions, to do business in or with Iran without violating economic sanctions.
- However, U.S. persons remain largely prohibited from doing business in or with Iran because the bulk of the U.S. trade embargo of Iran remains in place for U.S. persons.
The E.U. and U.N. also significantly pared pack their Iranian sanctions regimes. Combined, these changes allow non-U.S. persons to engage in most dealings with Iran without implicating U.S., E.U. or U.N. sanctions. Nevertheless, U.S. persons largely remain barred from transacting in or with Iran.