Jeremy Paner Discusses Potential US-Iran Deal and Implications of IRGC Involvement with Reuters

Jeremy Paner discussed with Reuters the outline of a potential U.S.-Iran deal and the implications of Islamic Revolutionary Guard Corps’ (IRGC) involvement in the oil sector.

The interim deal announced last week would authorize otherwise sanctioned oil sales, while a more comprehensive agreement in the coming months could lift additional sanctions and give Iran access to a $300 billion reconstruction fund.

Because Iranian investment law requires foreign companies to partner with local entities, a large number of IRGC-linked companies work as gatekeepers for investors entering the country’s most lucrative sectors. As a result, Western companies returning to Iran could find themselves operating alongside or through entities linked to the IRGC. Even without direct engagement with the IRGC, companies dealing in Iranian oil face significant sanctions risk exposure.

“The IRGC is the entity pulling all the strings behind the oil sector, so you can’t ignore all of the legal effects of doing business with them,” Paner said.

Even if the interim deal authorizes Iranian oil exports, Paner noted that “there’s still legal exposure for US companies because of the IRGC lurking in the background.” The U.S. Justice Against Sponsors of Terrorism Act, passed in 2016, allows victims of terrorist attacks to sue U.S. companies for aiding groups accused of terrorism, including the IRGC.

Paner also told Reuters that delisting thousands of entities designated for sanctions would take OFAC at least a year.

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