Client Alert August 2018 – IRAN: THE FIRST PACKAGE OF U.S. EXTRATERRITORIAL SANCTIONS AND THE UPDATE OF THE EU BLOCKING STATUTE

The first of the so called ‘wind down period’ stated by the US administration has expired on Monday, August 6, 2018. These wind down periods were established as a result of Trump’s pulling out from the Joint Comprehensive Plan Of Action, the ‘Iran nuclear deal’, on May the 8th this year.

Therefore, the first package of U.S. extraterritorial sanctions, which were suspended by effect of the JCPOA, will as consequence revive on August 7, 2018. On the same day, the European Union has published the update of the so called ‘Blocking Regulation’ (Reg. (EC) n. 2271/96 of the European Council) protecting against the effects of extra-territorial application  of U.S. rules – modifying the Annex to the mentioned Regulation -, as well as the Implementing Regulation and the Frequently Asked Questions (FAQ Q&A). Hereafter, we offer our comments and analysis on the EU approach.

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