Barbara Linney Quoted on Sanctions Policy Differences in WorldECR

"Mapping the Changes"

WorldECR

December 2018

Barbara Linney was quoted regarding the challenges facing businesses who wish to focus only on trade and transactions that will not attract sanctions enforcement risk. In addition to the difficulty of finding banks willing to finance legal exports to Iran, Linney said there are obstacles facing companies who want to make exports traditionally permitted by general licenses. "Part of the issue is that not all general licences are identical, so you have to be very mindful of the way in which you're using them – and not make assumptions based on the conditions of other licenses," she said.  She also noted that the lack of clear agency guidance tends to discourage transactions generally, as businesses are unable to envisage a bright line separating transactions that carry sanctions risk from those that do not.