Venable partner Ed Wilson was quoted in a July 14, 2015 Law360 article on the recently announced agreement with Iran aimed at curtailing the country's nuclear program. Under the deal, only sanctions enacted because of Iran’s nuclear program will be scaled back leaving others for terrorism, missile development and human rights violations in place. Additionally, the U.S. Treasury's Office of Foreign Assets Control (OFAC) said the U.S. would only scale back secondary sanctions applying to third-country parties and not U.S. firms.
According to Wilson, secondary sanctions were the most likely to be removed because they were the most recently enacted provisions and easier to lift. However, Wilson cautioned that the administration is likely to take its time removing the secondary sanctions. "OFAC is going to look at each person and entity on that secondary list to see if it is on the list for other reasons," he said. "Is it someone who just happened to be doing business with Iran for selling bathroom fixtures or is it somebody who is selling bathroom fixtures and using the profits to fund Hamas? They're going to look at those very closely and make a case-by-case call."