Key takeaways

• OFAC has clarified the scope of what U.S. companies may do in regard to Iran.
• U.S. banks may operate correspondent accounts for third-country banks that deal with Iran but may not process Iran-related transactions.
• U.S. companies may allow their foreign subsidiaries to establish a physical presence in Iran.
• Non-U.S. companies should adopt policies excluding U.S. directors and management from participating in Iran-related transactions.
• A company owned 50% or more by U.S. persons is treated as U.S.-owned, except for publicly traded companies with diffuse ownership.