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

Michael O'Kane

Michael was called to the Bar in 1992 and prior to joining Peters & Peters was a senior specialist prosecutor at the Crown Prosecution Service Headquarters (CPS). He was a key member of a small specialist unit responsible for the prosecution of serious and high-profile fraud, terrorist,...

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