5 July 2016
Please note that US jurisdiction-based or "primary" US Sanctions, administered by Office of Foreign Assets Control ("OFAC") require compliance by "US Persons", namely:
any person inside or outside the US who is a US citizen or green card holder;
any person within the US (even non-US citizen or green card holder); and
any entity organised under the laws of the US, as well as their foreign branches.
in the case of US sanctions relating to Cuba and Iran, the definition of "US Persons" also includes entities organised outside the laws of the US but that are US-owned or controlled (e.g. non-US subsidiaries of US entities).
Furthermore, US jurisdiction-based or "primary" US Sanctions, administered by OFAC may apply if the transaction involves the US financial system (e.g. processing USD payments or checks) and/or US-origin Goods (collectively "US Elements"). Against this background, the measures described in this Client Briefing require, in particular, specific legal advice if you are a "US Person" or if any intended transaction would contain any other "US Element".
Six months after the landmark nuclear deal with Iran, international sanctions against Iran have partially been lifted. Iranian and international businesses are keen to establish or expand trade and business relationships. Business travel and tourism have begun to increase considerably, providing an ideal basis for the resurgence of the Iranian hospitality market.