Contributing Lawyers


Cyndee Todgham Cherniak

United States

Susan Kohn Ross


Andrew Hudson

Iran Sanctions Take Effect

The sanctions imposed by the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, H.R. 2194, took effect on September 29, 2010, 90 days after enactment. As such, the general license that existed under 31 C.F.R. § 560.534 and permitted the importation of Iranian carpets and foodstuff will no longer apply after that date. While humanitarian aid is still allowed, the new legislation effectively stops all trade with Iran, although the President is permitted certain latitude, including regarding personal communications and information and informational materials as defined at 50 U.S.C. 1702(b). At the same time, exports of agricultural commodities, food, medicine, and medical devices are still permitted. Similarly, social networking connections are encouraged, whether involving hardware, software, or technology.

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