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OFAC has issued guidance in an FAQ on General Licence K as to which activities are considered “maintenance” in the conduct of Iran-related business. OFAC will consider past practices of parties to assess whether their conduct constitutes maintenance of a pre-existing contract / agreement. The guidance clarifies that there is no pre-existing relationship between the parties, or if the contemplated …
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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...
United States