The case of IRAN
The event with the most significant impact and influence of Organisations business with IRAN in managing of compliance programs is the Joint Comprehensive Plan of Action (JCPOA) signed on 14 July 2015, the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom and the United States, with the High Representative of the European Union for Foreign Affairs and Security Policy) and the Islamic Republic of Iran.
On May 8, 2018, the U.S. President announced his decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA), and to begin re-imposing, following a wind- down period, the U.S. nuclear-related sanctions that were lifted to effectuate the JCPOA sanctions relief.
EU, E3 (France, Germany and the United Kingdom) Russia, China, members of the Joint Commission of the JCPOA reiterated their political commitment to the full and continued implementation of the nuclear deal and support to maintain the normalization of trade and economic relations with Iran.
The complex and everchanging situation on santions on Iran requires the highest level of attention to all operators.
EIFEC since 2012 has built a solid base of knowledge on compliance issues and solutions.
In particular, having promoted and drafted in practice, the "Humanitarian Channel" mechanism included into the Geneva JPOA accord has an in-depth knowledge of all humanitarian focused trades mechanism with Iran.
EIFEC Washington Office operates in accordance with Compliance Services Guidance (the "CSG"), published by OFAC on January 12, 2017, and included in Cross-Programmatic Compliance Services Guidance section of OFAC Faqs.
In particular, OFAC states that U.S. persons may provide compliance services relating to the requirements of U.S. sanctions laws and conduct research to make a determination as to the legality of transactions under U.S. sanctions laws.
For the purpose of the Compliance Services Guidance only, EIFEC (Washington DC office) and personnel are U.S. covered persons.
EIFEC Head Office in Brussels maintains a broad institutional network of relationships and collaboratively participate in the drafting of the development of policies and regulations targeting Iran.