Advocate General Gerard Hogan's Opinion on EU-US Sanctions Dilema
Wednesday, May 26, 2021 In May 2018 the United States announced the reinstitution of sanctions against Iran that had previously been lifted pursuant to the Joint Comprehensive Plan Action (“JCPOA”).[1] The U.S. sanctions on Iran that were revived by the U.S. action in 2018 include many that apply extraterritorially. Moreover, U.S. law allows the government to impose sanctions on non-U.S. persons (such as European companies) if the U.S. Treasury Department makes a finding that the non-U.S. person has provided goods or services in support of a Specially Designated National of Ir...