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European Sanctions on Iran – Compliance for European Operations

Client Alert | 1 min read | 09.08.08

Recent news reports indicate that the EU is cracking down on small and mid-sized enterprises that are trading with and investing in Iran. There have been no new EU-wide rules since 7 August 2008 when the EU adopted a common position in order to implement United Nations Security Council Resolution 1803 (2008); however, there is increasing pressure on the EU and its Member States to enforce more stringently the existing UN sanctions as well as propose new measures with a broader scope.

In particular, EU authorities are attempting to target small and mid-sized companies and banks that do not have significant interests in the US and that are trying to fill the gap left by larger companies that have scaled down their Iranian operations.

As larger firms exit Iran, European businesses (and US businesses with European operations) will discover new business opportunities there. Exploring those opportunities, and determining whether they can be lawfully pursued, requires a review of the application of both US and EU law. That review must now take into account increased scrutiny by European authorities.

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Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....