By Maya Lester QC & Michael O’Kane

OFAC guidance on Iran snapback and amended General Licence J

Guidance: OFAC has amended its FAQ on the JCPOA nuclear deal with Iran as to what would happen if there were a “snapback” and sanctions were reintroduced (link here).  The updated answers, M.4 and M.5 say: The US will not retroactively impose sanctions for legitimate activity undertaken after Implementation Day, but the JCPOA does not grandfather contracts signed prior to...

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About Michael O'Kane

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Michael is Senior Partner at Peters & Peters LLP. He has acted in many of the most high profile and sensitive business crime cases of the last 25 years, at Peters & Peters LLP...

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