Doing Business in Iran Amid Evolving Sanctions: Leveraging New Opportunities While Ensuring Compliance

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, March 30, 2016

Recorded event now available

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Program Materials

This CLE webinar will provide guidance for counsel to U.S. companies considering doing business in or with companies in Iran. The panel will review sanctions that have been lifted and those that remain in place. The panel will also discuss how to ensure compliance with sanctions and customs requirements in order to take advantage of potential business opportunities in Iran.


On January 16, 2016, international sanctions related to Iran were substantially eased. “Implementation Day” ushered in a new compliance environment for companies seeking to take advantage of opportunities in the Iranian market, especially for non-U.S. entities owned or controlled by a U.S. person. With these new opportunities opening up in Iran, companies and their counsel must now navigate a complex intersection of international rules.

Despite the easing of Iran sanctions by both the U.S. and EU, important limitations remain, including the risk of imposition of new sanctions, as evidenced by designation by the Office of Foreign Assets Control’s (OFAC) immediately following Implementation Day of 11 additional individuals and entities in connection with support for Iran’s ballistic missile program.

Given the complex regulatory environment, it is essential for companies and their counsel to understand the applicable sanctions and export control hurdles and the steps that are necessary for compliance. In addition to the compliance risks, Iran’s failure to uphold its commitments could result in sanctions returning. Companies and their counsel should proceed with caution as they weigh new opportunities.

Listen as our authoritative panel addresses the evolving sanctions situation in Iran, what sanctions have been lifted, what continuing and new sanctions are in place, and what this means for companies currently doing or wanting to do business in Iran. The panel will discuss what general or specific licenses may be available when dealing with Iran, as well as applicable export controls and related issues.



  1. Sanctions—what’s been lifted and what remains
    1. U.S. sanctions
    2. EU sanctions
  2. Licenses
    1. General License H for non-U.S. entities owned or controlled by a U.S. person
    2. Licensing policy for commercial passenger aircraft, parts and services
    3. Importation of Iranian foodstuffs and carpets
    4. Other
  3. Export controls and related issues


The panel will review these and other key issues:

  • What business activities are permissible for U.S. companies with respect to Iran? How does the lifting of sanctions provide new opportunities for U.S. businesses?
  • What constraints does the General License impose on transactions in and with Iran for foreign companies owned or controlled by U.S. persons?
  • What steps should companies take to promote OFAC and export control compliance with respect to Iran?


Linney, Barbara
Barbara D. Linney

Miller & Chevalier Chartered

Ms. Linney advises U.S. and foreign clients across a broad spectrum of industries on international trade and business...  |  Read More

Nichola Peters
Nichola Peters

Addleshaw Goddard

Ms. Peters advises on and carries out investigations relating to corruption, sanctions, money laundering,...  |  Read More

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