law, conduct a broad range of transactions involving Iran, but it is essential to ensure that U.S. companies acting in conformity with this guidance can, under U.S. person officers, directors or employees are not involved in Iran-related business. companies, can adopt a general recusal policy to ensure that their U.S. companies, including these owned or controlled by U.S. Among other things, the updated JCPOA FAQs expressly affirms that non-U.S.
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