For many sanctions compliance officers globally, doing business with Iran is like tiptoeing through a mine field, taking care not to step on the United States’ ever-increasing sector-wide sanctions while simultaneously being cautious of conflicting statutes elsewhere in the world.
The Iranian sanctions risk landscape became even more convoluted on Jan. 10, with President Trump’s issuance of Executive Order 13902, which places additional sanctions on a much broader portion of Iran’s economy and—most notably from a compliance and risk management standpoint—places any non-U.S. company that does business with Iran in the crosshairs of U.S. sanctions where little to no such risk existed previously.
