17 gennaio 2020

Marazzi&associati is pleased to share a brief note on the sanctions system applied by the United States against Iran, based on the Iranian Transactions and Sanctions Regulations (ITSR), applicable when promoting or maintaining trade relations with Iran in certain economic sectors. This system includes primary sanctions applicable to U.S. physical and legal persons, US Persons, which prohibit any commercial transaction with Iran of any goods or technology of U.S. or foreign origin, either directly from the United States or through countries or third parties; and sanctions of a secondary nature, which can be imposed on any person regardless of nationality or domicile and have extraterritorial effect.

Foreign companies that have business relations with Iran and the United States at the same time are reminded to investigate in advance the Iranian physical and legal entities and verify that they have not been included in the American black-list, i.e. in the SDN list (Specially Designated Nationals List), published on the US Department of the Tresury website.

Finally, it should be recalled that branches or subsidiaries of US companies, being subject to US jurisdiction, will necessarily have to comply with the primary sanctions.

For more information you can contact Andreea Madalina Iordache: 

attached document