How continuing US sanctions on Iran impact non-US businesses and individuals doing business in Iran

The West’s sanctions on Iran changed significantly in mid-January as the EU and the UN relieved almost all restrictions. The US, however, has maintained a large number of its sanctions. Consequently, international companies that seek Iran business while continuing to rely on the United States – for financing, procurement, customers, or even the U.S. Dollar – must remain aware of these new complexities and the perhaps unseen continuing challenges of Iranian business.The upcoming ‘How continuing US sanctions on Iran impact non-US businesses and individuals doing business in Iran’ workshop given by Adam Smith, Gibson Dunn at the In-House Congress Middle East will describe some of the new potential opportunities allowed under sanctions relief (for US and non US persons, including subsidiaries of US parents); the continued prohibitions enforced by the United States; the mechanics of how sanctions relief is structured, can be accessed, and could be rolled back; and, will provide general guidance to allow both US and non-US participants to more confidently navigate this new sanctions reality. Continuing EU and US measures on Russia, and the recent changes to US sanctions on Cuba and Myanmar may also be discussed subject to delegate demand.

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Adam M. Smith, Of Counsel, Washington Office Gibson, Dunn & Crutcher
A former senior sanctions official in the Obama Administration, Smith played a primary role in briefing Congressional and private sector leadership on sanctions matters, shaping new Executive Orders, regulations, and policy guidance for both strengthening sanctions (Russia and Syria) and easing measures (Iran, Burma and Cuba), and advising on enforcement actions following sanctions violations. He is an experienced international lawyer with a focus on international trade compliance and white collar investigations, including with respect to federal and state economic sanctions enforcement, the Foreign Corrupt Practices Act, embargoes, and export controls.

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