Worldwide: "核协议履行日"触发了针对伊朗的国际制裁的重大变化(英文版)

International sanctions on Iran changed drastically on Saturday, January 16, 2016. After months of anticipation and speculation, the International Atomic Energy Agency ("IAEA") announced that it has verified that Iran has fulfilled its commitments under the Joint Comprehensive Plan of Action ("JCPOA"). This triggered Implementation Day, the latest and perhaps most significant milestone contemplated by the agreement reached on July 14, 2015, and the day on which the international sanctions relief contemplated by the JCPOA comes into effect. Although Implementation Day has undoubtedly been reached far earlier than originally predicted, United Nations, United States, and European Union authorities have promptly lifted certain international sanctions, as required by the JCPOA, and provided extensive guidance regarding the scope of the newly enacted sanctions relief. This lifting of sanctions significantly widens the scope of activities in which many international companies can engage with Iran, though many restrictions remain in place, particularly for U.S. companies.

The implementation of the JCPOA comes almost six months to the day after the EU, together with the U.S., the UK, Germany, France, Russia, and China (the "P5+1") reached an agreement with Iran regarding Iran's nuclear weapons development efforts. The JCPOA built on an April 2015 framework developed by the parties. That framework and the JCPOA committed Iran to undertake certain measures to prepare for and implement inspections and other processes to limit its ability to develop nuclear weapons in exchange for specified relief from international nuclear-related sanctions imposed over the past decade.

This Commentary provides a brief overview of the sanctions lifted on January 16 and the resulting regulatory changes for U.S., EU, and international companies.


Pursuant to the terms of UNSCR 2231 (2015) (which endorsed the JCPOA), all prior United Nations Security Council Resolutions mandating sanctions on Iran—namely, UNSCR 1696 (2006), 1737 (2007), 1747 (2007), 1803 (2008), 1835 (2008), 1929 (2010), and 2224 (2015)—were formally terminated upon receipt of the IAEA's report verifying that Iran has met its nuclear-related obligations under the JCPOA. All countries that are members of the UN are required to give effect to UN sanctions and will similarly now be able to withdraw these requirements within their jurisdictions. Through UNSCR 2231, the UN continues, however, to impose certain restrictions on nuclear-, conventional arms-, and ballistic missile-related activities involving Iran, and all UN sanctions remain subject to reimposition in the event of significant nonperformance by Iran of its commitments under the JCPOA.

As a result of Saturday's announcement, UNSCR 2231, in conjunction with the Treaty on the Non-Proliferation of Nuclear Weapons ("NPT"), is now the sole international legal framework addressing Iran's nuclear activities.


Upon confirmation of the IAEA's findings by U.S. Secretary of State John Kerry, the United States, through a combination of waivers, partial or complete revocation of executive orders, commitments to refrain from imposing sanctions measures, and agency findings, took three key steps on January 16 to fulfill its obligations under the JCPOA. First, the United States lifted its nuclear-related secondary, or extraterritorial, sanctions that had been imposed on certain Iranian industries, services, and trade. Second, the United States removed certain individuals and entities identified in the JCPOA from its sanctions-related prohibited parties lists. Finally, the United States implemented a general license to permit certain activities involving entities owned or controlled by U.S. persons, announced that it would be adding a general license for the import of Iranian-origin carpets and certain foodstuffs to the United States, and issued a Statement of Licensing Policy related to the export or re-export to Iran of commercial passenger aircraft and related parts and services.

Notably, with limited exceptions, the sanctions relief implemented on January 16 does not apply to U.S. persons. Indeed, substantial U.S. sanctions impacting U.S. and non-U.S. persons remain in force. In addition, all U.S. sanctions lifted on January 16 may be reimposed in the event of significant nonperformance by Iran of its obligations under the JCPOA. Accordingly, careful review of these changes to U.S. sanctions against Iran and forward-looking protections in the event of the reimposition of sanctions should be considered before proceeding with any course of action.

Lifting of Nuclear-Related Secondary Sanctions

As of January 16, the United States lifted secondary sanctions applicable to non-U.S. persons for the following general categories of activities:

  • Certain financial or banking activities, including transactions involving specified designated individuals and entities; transactions involving the Iranian rial; transactions involving the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt, including government bonds; and provision of specialized financial messaging services to designated entities;
  • Provision of certain insurance, reinsurance, and underwriting services;
  • Certain activities related to Iran's energy sector, such as investment, including participation in joint ventures, provision of goods, services, information, technology, and technical expertise and support; the purchase, acquisition, sale, transport, or marketing of Iranian petroleum, petrochemical products, and natural gas; the exportation, sale, or provision of refined petroleum and petrochemical products to Iran; and transactions involving certain designated entities;
  • Certain activities related to Iran's shipping and shipbuilding sectors and port operators;
  • Activities related to trade in gold and other precious metals;
  • Activities related to trade in graphite, raw or semi-finished metals (such as aluminum and steel), coal, and software for integrating industrial processes; and
  • Activities related to the sale, supply, or transfer of goods or services used in connection with Iran's automotive sector.

Accordingly, non-U.S. persons will no longer be subject to U.S. sanctions measures should they engage in these formerly sanctionable activities.

Removal of Certain Designated Persons from U.S. Sanctions Lists

The United States has also removed more than 400 individuals and entities specifically set out in the JCPOA, including the Central Bank of Iran and certain other specified Iranian financial institutions, from the List of Specially Designated Nationals and Blocked Persons (the "SDN List"), the Foreign Sanctions Evaders List (the "FSE List"), and the Non-SDN Iranian Sanctions List maintained by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"). Consequently, as of January 16, non-U.S. persons are no longer subject to the imposition of sanctions for engaging in transactions with any individual or entity removed from these lists, as long as the transactions involve neither individuals nor entities still designated on the SDN List or activities that continue to be subject to certain remaining U.S. sanctions, such as activities related to proliferation of weapons of mass destruction or support for international terrorism.

Licensing Regimes

The United States has taken steps to license or permit licensing for three categories of activities.

General License Authorizing Activities by Non-U.S. Persons Owned or Controlled by U.S. Persons. OFAC issued a general license, effective on January 16, authorizing, subject to certain restrictions, entities owned or controlled by U.S. persons to engage, directly or indirectly, in transactions involving Iran. As a result, foreign subsidiaries of U.S. persons are now permitted to engage in many transactions involving Iran that were previously prohibited by U.S. sanctions, and will not require a specific license to do so.

Further, this general license authorizes U.S. persons to engage in certain otherwise prohibited activities that may be necessary to facilitate these newly authorized activities. Specifically, U.S. persons are authorized to engage in:

  • Activities related to establishing or altering operating policies and procedures to the extent necessary to permit U.S.-owned or -controlled entities to engage in activities covered by the general license; and
  • Activities to make available to U.S.-owned or -controlled entities any automated and globally integrated computer, accounting, email, telecommunications, or other business support systems, platforms, databases, applications, or servers necessary to store, collect, transmit, generate, or otherwise process documents or information related to activities covered by the general license.

Pursuant to the general license, U.S. persons are also permitted to be involved in the initial determination to engage in activities in Iran authorized by this general license and provide training and counseling regarding any new or revised policies or procedures, but otherwise remain prohibited from being involved in the day-to-day operations associated with such activities.

In addition to the limitations on the involvement of U.S. persons in the Iran-related activities of their foreign subsidiaries, this general license imposes several other key restrictions. Specifically, the general license does not authorize U.S.-owned or -controlled entities to engage in transactions involving, among others:

  • The export, re-export, sale, or supply, directly or indirectly, of any goods, technology, or services from the United States to Iran without authorization;
  • Any activity involving any item (including information) subject to the Export Administration Regulations ("EAR"), 15 C.F.R. Parts 730-774, that is prohibited or requires a license under the EAR's end-user and end-use restrictions;
  • Participation in any transaction involving any person whose export privileges have been denied pursuant to Part 764 or 766 of the EAR;
  • Any transfer of funds to, from, or through the U.S. financial system;
  • Any persons on OFAC's SDN List, FSE List, or military, paramilitary, intelligence, or law enforcement entity of the Government of Iran or their officials, agents, or affiliates;
  • Any activities prohibited by remaining U.S. sanctions on Iran related to proliferation of weapons of mass destruction, support for international terrorism, and human rights abuses, or any other U.S. sanctions programs, including, specifically, U.S. sanctions pertaining to Syria and Yemen; and
  • Any nuclear activities involving Iran that are subject to the procurement channel established pursuant to UNSCR 2231 that have not been approved through the required process.

U.S. persons will be held liable and subject to civil penalties if foreign entities they own or control engage in activities outside those authorized under the general license.

General License Authorizing the Import of Iranian-Origin Carpets and Foodstuffs. OFAC has further announced that it will be adding a general license authorizing the importation of Iranian-origin carpets and certain foodstuffs, including pistachios and caviar, into the United States, and certain related services, including processing associated letters of credit and acting as a broker to such transactions. This general license will apply to certain categories of Iranian-origin carpets and foodstuffs, based on Harmonized Tariff Schedule classification. All goods covered by the general license will remain subject to all other applicable laws and regulations, including those administered by the Departments of Agriculture or Commerce, the Food and Drug Administration, and Customs and Border Protection. Significantly, this general license will become effective only upon publication in the Federal Register, and all covered transactions undertaken before that time remain prohibited.

Licensing Policy for Activities Related to the Export or Re-export of Commercial Passenger Aircraft and Related Parts and Services to Iran. Finally, OFAC has issued a Statement of Licensing Policy, effective as of January 16, permitting the issuance of licenses on a case-by-case basis that authorize the export, re-export, sale, lease, or transfer of commercial passenger aircraft and related spare parts and components to Iran for civil aviation use, and the provision of associated services, including warranty, maintenance, and repair services and safety-related inspections. Certain transactions covered by this Statement of Licensing Policy may also require separate authorization from the U.S. Department of Commerce's Bureau of Industry and Security.

Substantial U.S. Sanctions Remain in Place

Notwithstanding the significant sanctions relief provided pursuant to the JCPOA on Implementation Day, substantial U.S. sanctions remain in place that will continue to prohibit or penalize activities by U.S. and non-U.S. persons.

Most significantly, U.S. primary sanctions have not been lifted in connection with Implementation Day and remain in force. Consequently, very little has changed for U.S. persons, including U.S. companies, as a result of Implementation Day. These sanctions not only prohibit U.S. persons from engaging in virtually all transactions or other dealings directly or indirectly involving Iran without authorization, but also, significantly, apply to certain activities by non-U.S. persons, including the re-export of certain U.S.-origin or -controlled goods, technology, and services, and efforts to evade, avoid, or cause a U.S. person to violate U.S. sanctions. In addition, non-U.S. companies (including non-U.S. financial institutions) may not have access to or otherwise use the U.S. financial system in connection with any dealings involving Iran, as U.S. financial institutions remain prohibited, pursuant to U.S. primary sanctions, from engaging in or facilitating any transactions directly or indirectly involving Iran. This prohibition includes so-called "U-turn transactions" in which U.S. financial institutions clear U.S. dollar-denominated transactions related to Iran but originating and ending in third-country financial institutions.

Certain U.S. secondary sanctions also continue to remain in force. Even after Implementation Day, non-U.S. persons remain subject to the imposition of U.S. sanctions if, for example, they engage, directly or indirectly, in significant transactions involving: (i) Iranian persons that are on the SDN List; (ii) Iran's Revolutionary Guard Corps or its officials, agents, or affiliates; and/or (iii) any person designated on the SDN List in connection with Iran's proliferation of weapons of mass destruction or their means of delivery or support for international terrorism. Notably, the United States retains the authority to designate individuals and entities on the SDN List. Indeed, on Sunday, January 17, 2016, only one day after Implementation Day, the United States added eight individuals and three entities to the SDN List in connection with recent Iranian ballistic missile development activities. Further, trade in certain materials that are outside the scope of the JCPOA and related waivers remain subject to U.S. sanctions.

As a result, all companies that intend to engage in business in Iran would be prudent to continue to carefully monitor the remaining and developing scope of U.S. sanctions.


As of Implementation Day, the bulk of sanctions previously imposed by the European Union on Iran relating to nuclear proliferation have been lifted. Nonetheless, a mixture of EU human rights-related sanctions and some remaining nuclear-related sanctions continue to remain in force.

EU Legal Framework Leading to Implementation Day

The EU sanctions in place with respect to Iran are twofold. First, the European Union has a set of sanctions in place that relate to the human rights situation in Iran, which are implemented through Council Decision 2011/235/CFSP and Council Regulation (EU) No 359/2011. Second, the European Union imposed sanctions with respect to its concerns regarding Iran's nuclear program, which are enacted through Council Decision 2010/413/CFSP and Council Regulation (EU) No 267/2012.

As of October 18, 2015 (Adoption Day), the European Union adopted the legislative instruments—namely, Council Decision (CFSP) 2015/1863, Council Regulation (EU) 2015/1861, and Council Implementing Regulation (EU) 2015/1862—necessary to enact the relevant amendments to lift EU nuclear-related sanctions on Iran pursuant to the JCPOA. Application of this legislation, however, was made contingent on the EU Council's confirmation that the Director General of the IAEA presented a report to the IAEA Board of Governors and to the UN Security Council confirming that Iran took the necessary measures it committed to under the JCPOA. Upon receipt of that confirmation on January 16, the EU Council published Council Decision (CFSP) 2016/37, and as a result, the amendments to the EU nuclear-related sanctions regime enacted on Adoption Day became applicable, and the bulk of EU sanctions were lifted.

Similar to the United States, the European Union has largely implemented the sanctions relief required by the JCPOA by lifting or easing the bulk of its nuclear-related sanctions against Iran and removing certain specified individuals and entities from its sanctions-related prohibited parties lists. The lifting and easing of sanctions by the European Union is without prejudice to a possible reintroduction in the event of significant nonperformance by Iran of its commitments under the JCPOA. The EU Council, however, anticipates that in such a case, adequate protection for the execution of contracts concluded while sanctions relief was in force will be provided. Nevertheless, in the absence of specific guidance, it may be prudent to provide for adequate contractual protection should a snapback of sanctions occur.

Remaining Sanctions

While the bulk of the nuclear-related sanctions have, as of Implementation Day, been lifted or eased, certain EU sanctions nevertheless remain in force. In particular, Implementation Day has not lifted or eased all EU nuclear-related sanctions and does not have any bearing on EU human rights-related sanctions, which remain entirely unchanged and fully in force. The following provides a general overview of the EU sanctions currently remaining with respect to dealings directly or indirectly involving Iran:

  1. Prior authorization is required for transactions concerning items contained in the Nuclear Suppliers Group List, items that could contribute to reprocessing or enrichment-related or heavy-water-related or other activities inconsistent with the JCPOA, Enterprise Resource Planning software designed specifically for use in nuclear and military industries, certain graphite and raw or semi-finished metals, and items that may be used for the monitoring or interception of internet or telephone communications.
  2. Prohibitions on transactions concerning items included in the Missile Technology Control Regime list, items included in the Common Military List (arms embargo), and items that can be used for internal repression.
  3. The prohibitions/restrictions referred to under (1) and (2) are accompanied by specific prohibitions on associated services (such as technical assistance, brokering services, financing, and financial assistance) and also include restrictions on EU persons from entering into or being involved in any arrangements that allow Iranian legal persons to participate or increase participations in these sort of activities. In addition, EU persons are also prohibited from providing bunkering, ship supply services, or any other services to vessels as well as from providing engineering and maintenance services to cargo aircraft, where such vessels or aircraft are owned or controlled by Iranian persons or entities and there are reasonable grounds to determine that they are transporting prohibited goods (subject to limited humanitarian and safety exceptions).
  4. Restrictions on admission to the European Union for listed (natural) persons and a prohibition on making funds or economic resources available, directly or indirectly, to or for the benefit of listed persons. Also, the supply of specialized financial messaging services used to exchange financial data to certain listed persons is prohibited. As with the previous Iranian-related sanctions, the risk of liability for EU persons who are indirectly involved in arrangements that breach the remaining Iranian sanctions remains a concern. The number of listed persons is, however, substantially reduced.

Accordingly, even though EU nuclear-related sanctions have been substantially lifted or eased, EU persons must continue to take steps to ensure they remain in compliance with applicable restrictions in any dealings involving Iran.

Lifting or Easing of Nuclear-Related Sanctions

Those who are familiar with the scope of the EU sanctions that were previously in place will notice from the general overview provided above that several key restrictions and prohibitions have been lifted or significantly eased. For instance, the EU sanctions no longer prohibit dealings involving dual-use items with respect to Iran or Iranian entities. Of course, export of dual-use items will remain subject to the general dual-use framework (as laid down in Council Regulation (EC) No 428/2009). Moreover, certain dual-use items are contained in the Nuclear Suppliers Group List, and for those items, an authorization will still be required pursuant to the remaining EU sanctions on Iran. The EU sanctions also no longer provide for restrictions on transfers of funds or on the export of gold, precious metals, and diamonds. Other examples of important restrictions or prohibitions that have been lifted or eased relate to the oil, gas, petrochemicals, finance, banking, and insurance industries.

Removal of Certain Designated Persons from EU Sanctions Lists

Pursuant to the JCPOA, the European Union has also removed numerous individuals and entities from its sanctions lists. As a result, as of January 16, EU persons are no longer prohibited from engaging in dealings with such persons but must remain vigilant for the numerous individuals and entities that remain designated on applicable lists, including in respect of indirect dealings.


Jones Day continues to closely monitor developments associated with the JCPOA and the recently implemented sanctions relief provided on Implementation Day. As can be seen from the above, challenges remain for organizations who intend to explore opportunities and/or do business in Iran while remaining in full compliance with international sanctions regimes. At the same time, the legacy of previous Iranian sanctions regimes (including contractual agreements not to do business in Iran that may now need to be amended) will continue to be a focus of transaction teams, general counsel, and compliance officers for some time to come.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

Fahad Habib
Harriet Territt
In association with
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.