Focus on New Iran Secondary Sanctions and Enforcement

November 14, 2018 1:30pm

Mandy Palmer
Managing Director and Head of Banking, Financing & Securitization Paris-London
Credit Agricole Corporate and Investment Bank (UK)

Discussion Leader

Nicole Erb
Partner, Washington, DC
White & Case (USA)

Karen Walter
Head Compliance Regulatory & Advisory
Allianz SE (Germany)

Nicholas Bentley
Senior Legal Counsel Trade Sanctions
Novartis (Switzerland)

Spencer Chilvers
Head of Export Control Policy
Rolls-Royce (UK)

Chris Po-Ba
Lloyd's
(UK)

  • Wind-down risks: Is the termination of agreements your only option? Would a suspension be enough? Could executed contracts, under which only warranty obligations remain, be put dormant?
  • Distinguishing how OFAC treats cases with:
    • entities with direct presence in Iran through a subsidiary
    • entities with a JV with an Iranian party
  • Executing payments in the environment when financial institutions, insurance companies and their counterparties are derisking in relation to Iran