Barbara Linney Quoted on Potential Impact of JCPOA on U.S. Business in International Bar Association Global Insight

"Sanctions: Iran deal offers limited relief with strings attached"
International Bar Association Global Insight
August/September 2015

Barbara Linney was quoted regarding the potential impact of the recent Joint Comprehensive Plan of Action (JCPOA) deal, which will lift sanctions on Iran in exchange for a promise that the country will not engage in nuclear weaponry. Linney said the long-term impact of the JCPOA on U.S. businesses will be minimal. She explained that even after Implementation Day, when the International Atomic Energy Agency has certified Iran's compliance with key nuclear-related measures described in the JCPOA, there will only be limited relief for U.S. businesses, principally in the form of sanctions relief for the commercial passenger aircraft sector.

In addition, after Implementation Day, the U.S. has pledged to allow imports of some Iranian-origin items and to allow non-U.S. entities that are owned or controlled by U.S. persons to engage in activities that are consistent with the JCPOA. While the deal does not provide much detail about this, it might include "activities of U.S.-owned or controlled foreign entities in industries for which secondary sanctions will be lifted," she said.

Although the JCPOA addresses investigations into past violations of sanctions, it does not say anything about pending U.S. enforcement actions over breaches of embargoes or of dual-use export controls. "Such violations are subject to civil and criminal penalties," Linney said, "and we do not expect the JCPOA to have any impact on enforcement proceedings related to such violations."

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