Exports Controls Laws and Regulations

In the Global Trade World of today, there are many restrictions in place in who the deal with and what to export, re- export or import. 

Principally and due to the specific situation  as well as past years experiences of Iran, such concern truly increases when interacting with Iran.

Back ground: 


Concerns about the inappropriate transfer of new information, technologies, and products with military applications outside the U.S. have led to the passage of two laws in the late 1970's that control exports of selected technologies and products.

These regulations are designed to: control and restrict export , import and re- expert of  any product, technology or service that might be used by a restricted country/ person that might have a military / terrorist or dual-use application.     

US Sanctions: 

For almost last four decades Iran has been subject to US sanctions which during the time have been densified or relaxed. 

The main restriction  when it comes to Iran_US sanctions-a.k.a : Primary Sanctions-  consider is that: ‚Äúproviding ANY services or product from a US person (that it includes both US citizens and green- card holders),to Iran or any company based within Iran is prohibited unless exempted to authorized based on separate OFAC license. 

JCPOA and effects on Sanctions: 

By signing the nuclear deal, there has been a major lift of sanctions only affected what  was known as Secondary Sanctions, by which and prior to the JCPOA , other non- US persons dealing with Iran could also face sever penalties consequent to violence of US Exports Controls. 

In light of such relaxation in the sanctions, the EU as well as companies from across the world are legally allowed to do business with Iran without fearing any major penalty. 

That being said, the validity of the JCPOA now remains in the hands of US congress upon President Trump administration decision.

US companies: 

Under the recent General License issued after the JCPOA, the US companies are allowed to operate and work within Iran as long as: 

1. They are not a subsidiary of the US affiliate

2. No US person provides services to the business of Iran. 

Other Sanctions: 

Following to the nuclear deal and singing of JCPOA, other sanctions related to Iran nuclear activities, imposed against Iran by EU, UN and UK were immediately lifted with immediate effect. 

Black- listed persons(SDN): 

In despite of the fact that the sanctions have been partially lifted against Iran yet other sanctions non- related to nuclear activities (i.e.: human rights, ballistics ) remain valid and there many companies/ person remained in the black list of sanctions consequently. 

Those working with Iran, need to always ensure that while doing business with Iran , they remain diligent not to avoid applicable sanctions.     

Penalties for Non-Compliance

US sanctions regulations, authorize stiff penalties for violations and non-compliance and include the following administrative, civil, and criminal. 

For more information about sanctions compliance in Iran, contact us. 


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