1. Home
  2. |Insights
  3. |New Certification of Iran Sanctions Compliance - for You and Your Subsidiaries

New Certification of Iran Sanctions Compliance - for You and Your Subsidiaries

Client Alert | 1 min read | 10.06.10

On September 29, 2010, the FAR Council published an Interim Rule with request for comment implementing the requirement in the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 ("CISADA") that every contractor certify that neither it, nor any entity owned or controlled by the contractor, engages in any activity for which sanctions could be imposed under section 5 of CISADA, including, for example, sales of goods, services, or technology that could directly and significantly facilitate the maintenance or expansion of Iran's domestic production of refined petroleum products. While the CISADA sanctions extend to both U.S. and foreign persons -- and the FAR Council has extended the certification requirement as broadly as possible to include procurements of commercial items, COTS items, and those below the simplified acquisition threshold -- to avoid any conflict with the U.S.'s commitments under the WTO Agreement on Government Procurement and other free trade agreements, contractors furnishing only "designated country" end products under a contract subject to the Trade Agreements Act are exempted from the certification requirement.

Insights

Client Alert | 8 min read | 06.06.25

Litigation Funding Reforms: Clarity for UK Funders and Litigants Post-PACCAR

On 2 June 2025 the Civil Justice Council (a UK public body that advises on civil justice and civil procedure) (“CJC”) issued its Review of Litigation Funding Final Report (the “Report”). The CJC has provided comprehensive recommendations on the regulation and reform of litigation funding in England and Wales. The highlight recommendation of the Report is for the UK Government to remove third party litigation funding from the regulations and requirements of the Damages-Based Agreements Regulations 2013 (“DBA Regulations”), reversing the judgment of the Supreme Court in PACCAR.[1] Meanwhile, the UK Court of Appeal has recently endorsed a position that the Competition Appeal Tribunal (“CAT”) may order that third party funders of collective proceedings be paid first from litigation proceeds before claimants according to waterfall provisions in their funding agreements....