U.S. sanctions against Iran have limited trade between foreign and Iranian companies for decades. The 2015 nuclear agreement eased sanctions by widening the scope of permitted business dealings, but brought attendant risks to foreign companies considering venturing into Iran. This Essay proposes that companies can employ a risk-reward model to assess whether the opportunity posed by a proposed venture justifies the risks of violating sanctions laws. The Essay suggests that companies can create a model by categorizing and quantifying the likely benefits of a business deal and compare the opportunity with risks, after implementing processes to limit specific risks. The Essay draws upon relevant sanctions laws and the history of violations to highlight some of the pitfalls that corporations and financial institutions may encounter under the recent loosening of sanctions.
Talib Amir, Iran Sanctions: A Compliance Perspective the Promise and Peril of Entering the Islamic Republic, 23 FORDHAM J. CORP. & FIN. L. 503 (2018).