The Trump administration has put in place a wave of tougher economic sanctions against Iran, including new secondary sanctions against non-U.S. financial institutions that conduct major financial transactions in certain sectors of Iran`s economy. (See our legal update.) On the other hand, Europe is trying to save the remnants of the non-proliferation agreement through an economic commitment, although EU member states have fought for useful concessions to Iran in the face of US opposition. 7 Interpretation note of FATF Recommendation 19, available at www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF%20Consécence%202012.pdf. 5 Public statement – October 2019, Financial Action Task Force (October 2019), available at www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/public-statement-october-2019.html. On January 10, 2020, the United States confirmed that, after an initial phase of resolution, “the United States will fully reinstate the sanctions it has lifted under this agreement, including a ban on foreign subsidiaries of U.S. companies from acting with Iran and the imposition of secondary sanctions against foreign companies that conduct certain Iran-related transactions.” 1 Press release on Iran`s commitments to the Financial Action Task Force, Secretary of State Michael R. Pompeo (February 12, 2020) [hereafter the “press release,” available from www.state.gov/irans-commitments-to-the-financial-action-task-force/. The press statement was attributed to U.S. Secretary of State Pompeo, but was issued by the U.S. Department of State`s Bureau of Economic and Business Affairs, the Department of Financial Financing and Sanctions Against Threats (“TFS”), which oversees the State Department`s international engagement on AML/CFT issues, including the Financial Action Task Force. TFS is also responsible for the development and implementation of sanctions to combat domestic security threats and to provide foreign policy guidance to the U.S. Treasury and the U.S.
Department of Commerce. A limited number of EU sanctions against Iran have already been suspended as a result of the interim agreement between China, France, Germany, Russia, the United Kingdom and the United States with the European Union`s High Representative for Foreign Affairs and Security Policy; The Joint Action Plan of 24 November 2013 presented an approach to a comprehensive long-term solution to the Iranian nuclear issue.