Presenting a live 90-minute webinar with interactive Q&A Back to Business in Iran After the Nuclear Deal: Maximizing Opportunity and Minimizing Liability Risks Navigating Remaining Sanctions and Customs Controls, Obtaining Necessary Licenses, and International Tax Planning TUESDAY, OCTOBER 13, 2015 1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific Today’s faculty features: Mehrdad Ghassemieh, Partner, Harlowe & Falk, Tacoma, Wash. Nnedinma C. Ifudu Nweke, Senior Counsel, Akin Gump Strauss Hauer & Feld, Washington, D.C. Barbara D. Linney, Member, Miller & Chevalier Chartered, Washington, D.C. David B. Woodward, President & CEO, Associates in Cultural Exchange, Seattle The audio portion of the conference may be accessed via the telephone or by using your computer's speakers. Please refer to the instructions emailed to registrants for additional information. If you have any questions, please contact Customer Service at 1-800-926-7926 ext. 10. 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A link to the Attendance Affirmation/Evaluation will be in the thank you email that you will receive immediately following the program. For additional information about continuing education, call us at 1-800-926-7926 ext. 35. Program Materials FOR LIVE EVENT ONLY If you have not printed the conference materials for this program, please complete the following steps: • Click on the ^ symbol next to “Conference Materials” in the middle of the left- hand column on your screen. • Click on the tab labeled “Handouts” that appears, and there you will see a PDF of the slides for today's program. • Double click on the PDF and a separate page will open. • Print the slides by clicking on the printer icon. David B. Woodward President & CEO Associates in Cultural Exchange 1856 -The Treaty of Commerce and Navigations signed (lasted until 1926) between the U.S. & Persia 1856 – Nasserredin Shah Qajar of Persia sent 1st Persian ambassador to the U.S., Mirza Abolhassan Shirazi 1883 – Samuel Benjamin 1st U.S. envoy appointed to Persia under the title American Minister to Persia 1908 – Oil discovered in SW Persia by British speculator, Willam D’Arcy 1909 – Anglo-Persian Oil Company Established 1909 – Howard Baskerville, American missionary, died attempting to support the constitutional revolution 6 1911 – American financial consultant, Morgan Shuster, appointed by Persian parliament Treasurer General of Persia 1911 – British and Imperial Russian governments force Persia to expel Shuster from office 1921 – British coup installs Reza Shah Pahlavi as commander in chief of military 1925 – Reza Shah Pahlavi assumes role of Shah of Iran 1941 –British and Soviets invade Iran; Reza Shah deposed & son Mohammad Reza installed as new Shah 7 1947 – Post WWII Cold War era begins & U.S. begins to counter Soviet interests in Iran 1951 – Mohammad Mosaddegh appointed Prime Minister of Iran, nationalizes Anglo-Iranian Oil Company (later British Petroleum) 1952 – unknown to Truman, CIA office in Tehran begins covert activities designed to remove Mosaddegh from office 8 1953 – CIA instigates overthrow of Mossadegh via “Operation Ajax”; Mohammed Reza Shah returns from brief exile; U.S. consolidates control over Iranian affairs . Madeleine Albright, U.S. Secretary of State commenting on the overthrow of Mossadegh in 2000 said “In 1953 the United States played a significant role in orchestrating the overthrow of Iran's popular Prime Minister, Mohammad Mossaddegh. The Eisenhower Administration believed its actions were justified for strategic reasons; but the coup was clearly a setback for Iran's political development. And it is easy to see now why many Iranians continue to resent this intervention by America in their internal affairs.” 1953 – 1973 a period of stability in U.S. – Iran relations; rise of Mohammad Reza Shah as regional leader; vast growth in oil wealth; modernization & suppression of intellectuals and religious leaders 1957 – U.S. initiates nuclear Atoms for Peace in Iran 9 1974 – 1979 Post Yom Kippur war and subsequent OPEC Oil embargo of 1973, U.S. confidence in Mohammad Reza Shah wanes; the Shah becomes more autocratic 1979 - Islamic revolution in Iran causes Shah to go into exile in the U.S.; Ayatollah Ruhollah Khomeini assumes power and installs theocracy 1979 - Hostage crisis commences with takeover of U.S. Embassy by “students” and lasts from Nov 4, 1979 to Jan 20, 1981 1980 – “Operation Eagle Claw” fails to rescue hostages 10 1980 – 1988 – Iran–Iraq war launched by Iraq toward end of Carter administration; Reagan and Bush administrations actively supported Saddam Hussein’s government in war effort including authorizing sale of chemical & biological weapons 1983 – U.S. claims that Hezbollah bombings in Beirut were supported by Iran 1986 – Iran-Contra Affair - Reagan administration sells weapons to Iran to covertly support Nicaraguan rebels 1987 & 1988 – U.S. naval attacks on Iranian oil facilities 1988 – USS Vincennes shoots down Iran Air Flt 655 killing 290 civilians 11 1989 – 1990 U.S. continues support for Saddam Hussein regime 1990 – Iraq invades Kuwait 1990 – 1991 – Gulf War; U.S. leads coalition to oust Iraq from Kuwait 1990 – 2003 – Sanctions imposed on Iraq 12 1995 – Total embargo imposed by Clinton administration 1998 – Newly elected President Khatami reaches out to U.S. to open dialogue 2000 – 4 U.S. Congressmen hold informal talks with 5 members of Iranian parliament in New York 13 2001 - 9/11; Bush states on 9/20/11 “Either you are with us, or you are with the terrorists.” ;U.S. invades Afghanistan 2002 – Bush gives “Axis of Evil Speech 2003 – U.S. invades Iraq 2003 – Iranian government proposes “Grand Bargain” to promote dialogue between U.S. & Iran, Bush administration rejects overture 2003 – IAEA launches investigation of Iran’s uranium enrichment program 2005 – 2008 U.S. escalates covert operations against Iran 2006 – U.S. passes Iran Freedom & Support Act 2007 – U.S. raids Iranian consulate in Irbil, Iraq 14 2009 – Presidential elections in Iran; Green Revolution; crackdown by Revolutionary Guard 2009 – U.S. hikers cross into Iran and arrested 2011-2012 – Iranian military leaders threaten closure of access to Persian Gulf 2013 – Hassan Rouhani elected president; visits UN in September, speaks with Obama by phone – 1st contact between heads of state in 34 years 2006 – 2015 P5+1 (UN Sec Council + Germany) negotiations with Iran conclude on July 14, 2015 2015 – Congress unable to pass resolution opposing nuclear deal 15 Key themes in U.S. – Iran relations include: . Mutual economic & social interests over 150 years . Mutual mistrust of Russian & British activities for 100 years . Iran as major source of oil . Iran as centerpiece of Western Cold War strategy . U.S. overthrow of constitutional government in 1953 . Iran’s attempts to reject external control . Islamic revolution . Hostage crisis . 36-year standoff . Nuclear deal . Political re-engagement 16 David B. Woodward President & CEO Associates in Cultural Exchange 200 West Mercer Street, Suite 108 Seattle, WA 98119 (206) 217-9644 [email protected] 17 Back to Business in Iran After the Nuclear Deal: Maximizing Opportunity and Minimizing Liability Risk U.S. Sanctions Considerations presented by Barbara D. Linney Member Miller & Chevalier Chartered October 13, 2015* Strafford Live CLE Webinar * This PowerPoint presentation covers developments through October 9, 2015, the cut-off date for submission to Strafford for distribution. Any subsequent developments will be covered during the live webinar. Agenda 1. U.S. sanctions prior to the Iran nuclear deal 2. U.S. sanctions relief under the deal 3. Timing of sanctions relief 4. U.S. sanctions after implementation of the deal 5. Potential licenses that must be obtained when dealing with Iran 6. Enforcement risks 7. Benefits and risks of deal for U.S. persons U.S. SANCTIONS CONSIDERATONS | 19 U.S. sanctions prior to the Iran nuclear deal . Primary and secondary sanctions regimes . Primary sanctions = comprehensive embargo • U.S. persons prohibited from engaging in most transactions with or for the benefit of Iran or persons in Iran - Limited exemptions (e.g., personal communications, travel, information and informational materials) and exceptions authorized by general or specific licenses (e.g., exports of agricultural commodities, food, medicine & medical devices) • Assets of Government of Iran and various specially designated nationals blocked under various OFAC programs . Secondary sanctions = actions against foreign persons who engage in sanctionable conduct • Most secondary sanctions authorized by legislation (e.g., Iran Sanctions Act,