John E. Smith, former director of the Treasury Department’s Office of Foreign Assets Control (OFAC) and co-head of Morrison Foerster’s national security practice, discusses the current Iran sanctions and their impact on global business. Since the U.S. withdrew unilaterally from the Iran nuclear deal, it has become an outlier, as much of the rest of the world, including Europe, wants to continue to do business with Iran.

Smith discusses the risk of sanctions fatigue as economic penalties become a more common tool for the administration. Smith also addresses how OFAC, a relatively small department within Treasury, is working on implementing the administration’s sweeping sanctions regime.

In terms of the private sector, the Iran sanctions have had an outsized impact on financial services – banks are becoming increasingly conservative as OFAC has asserted its influence on global companies through their banking transactions.

Smith offers tips for attorneys counseling global companies and financial institutions in this sanctions-rich environment.

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Hosts: Dori Goldstein and Meg McEvoy

Guest: John E. Smith, co-head of Morrison Foerster’s national security practice

Producer: RJ Jewell