In January 2016 the US Office of Foreign Assets Control adopted an important exemption for US companies in the context of the liberalisation of sanctions with Iran.
In the just published 2014 OFAC (*) Civil Penalties Information Chart four out of the ten companies who settled with the US authorities since January 2014 for alleged breaches of US trade sanctions are non-US companies. Three of them are EU companies.
Whereas the number of OFAC enforcement actions per year has been declining in the last decade, the financial amounts involved per year have been rising. Even though the biggest fines or settlements have usually been with financial institutions, other sectors, and both large and small companies as well as private individuals can and do get hit by US measures.
The UK Government has imposed additional sanctions against Iran. National measures were adopted under Schedule 7 to the Counter-Terrorism Act 2008 and entered into force at 3 pm on 21 November 2011.