Overview
Steptoe partner Meredith Rathbone was cited in a Global Investigations Review article titled “Epsilon Should Be Given ‘No Refuge’ Under Grey Area of Iran Sanctions Law.” The article, published September 17, discusses a guidance issued by the US Office of Foreign Assets Control (OFAC) in 2002 claiming US-based companies are sometimes permitted to sell their goods to a foreign business that trades with Iran, in what’s called the “inventory exception.”
Ms. Rathbone tells Global Investigations Review that OFAC has declined, when asked about conferences, to define exactly what it means for a company to predominantly do business with Iran. The inventory exception fails to apply if a US company trades with a foreign business that predominantly deals with Iran. OFAC has only stated that it depends on the facts, and that even if a company makes well below 50 percent of its sales to Iran, this can still count as “predominantly” dealing with the country.
The full article can be read at Global Investigations Review (subscription required).