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Transatlantic Compliance Challenges in the JCPOA
Two months after the implementation of the Joint Comprehensive Plan of Action (JCPOA) and the consequent removal of nuclear-related sanctions, EU companies and banks remain confused and hesitant about dealing with Iranian entities. Despite the guidance issued both by the US and the EU, and assurances from the US Treasury’s Office of Financial Assets Control, European financial institutions continue to be concerned about breaching enduring US sanctions and face restrictions on dollar clearing. Many EU companies tempted by Iran are holding back as a result of consequent difficulties in financing prospective investments, and because of the prospect that sanctions are ‘snapped back’ with few commercial protections.
To explore this in more detail, Richard Nephew, former Director for Iran on the National Security Staff and principal deputy coordinator for sanctions policy at the U.S. State Department, and Michael Lyons, Senior Associate at Clifford Chance, will examine the challenges faced in the US and in the EU in dealing with the operational aspects of the JCPOA. Furthermore, they will explore whether and on which issues transatlantic friction exists, and what steps could be taken on both sides of the Atlantic to encourage legitimate business with Iran.
The panel will be moderated by Andrea Berger, Deputy Director and Senior Research Fellow on Proliferation and Nuclear Policy at RUSI.
This event is free and open to all. For any questions, please contact Hannah Croft, Projecty Officer, at HannahC@rusi.org.
Richard Nephew is the Program Director of Economic Statecraft, Sanctions and Energy Markets at the Center on Global Energy Policy. Prior to that, he was the Principal Deputy Coordinator for Sanctions Policy at the Department of State. Nephew also served as the lead sanctions expert for the U.S. team negotiating with Iran and, from May 2011 to January 2013, served as the Director for Iran on the National Security Staff, where he was responsible for managing a period of intense expansion of U.S. sanctions on Iran. Earlier in his career he served in the Bureau of International Security and Nonproliferation at the State Department and in the Office of Nonproliferation and International Security at the Department of Energy.
Michael Lyons is a Senior Associate at Clifford Chance. He provides specialist advice on international financial and trade sanctions issues to financial institutions, corporate enterprises and other clients. In recent years he has been advising in depth on issues arising as a result of the EU and US sanctions imposed in relation to Iran and Russia among other regimes, co-ordinating with Clifford Chance's Washington DC office on US issues. He has also advised on litigation with sanctions issues, including an ongoing case related to frozen funds of the Iranian Government, and has co-authored a number of client publications.