Sanctions Risk

The adoption of the JCPOA does not end all sanctions imposed against Iran, its agents, and nearly all of its state-owned businesses. The relaxation of U.S. sanctions against Iran is, with a few exceptions, limited to non-U.S. persons. U.S. persons and companies 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 and companies.


Broad sanctions relating to Iran’s sponsorship of international terrorism and human rights violations remain in effect and are unaffected by Iran’s stated decision to curtail its nuclear activities.  According to the U.S. Treasury Department, “more than 200 Iran-linked companies and individuals will remain designated by the United States and subject to direct U.S. and secondary sanctions [outside of U.S. jurisdiction].”  


The penalties imposed for violating sanctions are significant, including asset freezes, prohibitions on transactions with the U.S. financial system, and bans on importation of U.S.-origin goods.  Civil or criminal penalties may also be assessed under the U.S. Anti-Terrorism Act and the Iranian Transactions and Sanctions Regulations, which authorize sanctions on any persons, including U.S.-based companies, who provide financial, material or technological support to or on behalf of foreign persons designated for involvement in acts of terrorism that threaten U.S. national security.