All U.S. sanctions on Iran that were lifted or waived as part of the Iran nuclear deal were re-imposed effective November 5, 2018. Washington, D.C.-based law firm Akin Gump has released a lengthy analysis and description of the ins and outs relating to the return of Iran sanctions to global trade in oil and other goods.

The NDAA 2012 provides that sanctions do not apply to foreign financial institutions located in a country of primary jurisdiction that has “significantly reduced” Iranian crude oil purchases from Iran during the previous 180-day period.

In addition, Section 3(b)(ii) of EO 13846 provides that non-U.S. persons located in countries who obtain a Significant Reduction Exception, or SRE, may engage in significant transaction...

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