Overview
Thanks to all of the speakers and attendees at our December 10 London seminar “Transatlantic Perspectives on the Iran Nuclear Deal and Sanctions Compliance.”
Approximately 170 attendees joined to hear the advertised keynote speaker Adam Szubin, US Treasury Acting Under Secretary for Terrorism and Financial Intelligence (and former OFAC Director), and to hear further remarks from Francesco Fini, Head of Sanctions Team for the European External Action Service.
Following the remarks from Szubin and Fini, lively panel discussions included government officials, trade association experts, and counsel experienced in US and EU sanctions issues.
The seminar was closed to press and subject to non-attribution rules, but without overstepping these lines it’s fair to say that a key set of points to emerge is the following:
- Many stakeholders want and expect an Iran that is re-engaged with the business world;
- The anticipated changes to the sanctions rules should allow significant re-engagement by non-US persons and companies, within parameters;
- But this will be complicated and require careful assessment of legal risks in light of an array of limitations, including continuing US primary sanctions on US persons, residual US secondary sanctions applicable to non-US persons for non-nuclear reasons, and US export/re-export controls; and
- Patience, and a willingness to slog through nuanced rules, will be required on all sides.
