Dubai: The UAE is at the forefront of issues relating to the US sanctions on Iran, according to a former senior official.

In his lecture at the Dubai School of Government, Hal Eren, a former legal adviser to the US Treasury Department, discussed the legal framework of the Comprehensive Iran Sanctions, Accountability and Divestment Act 2010 (CISADA).

Since the UAE has significant trade links with Iran, he said, many of its businesses will be subject to the sanctions.

"The UAE measures should be consistent with the UN Security Council Resolution and some criteria in the CISADA should clarify what is black and what is white, in terms of legal measures of doing business with Iran," he said.

Eren presented a chronology of the US economic sanctions against Iran which go back 30 years.

He later detailed how the CISADA has broadened the sanctions against Iran by imposing sanctions on non-US and non-Iranian businesses which invest or engage in trade transactions with Tehran.

Another way to better understand CISADA, Eren said, is to think: "The friend of my enemy is my enemy."

"Join the United States and US companies in abstaining from the Iran petroleum sector or else you may become a US sanctions target and suffer all the consequences flowing from such status. Choose between the United States policy and doing business with Iran," he said, calling on all foreign or non-US companies.

The official pointed out that, according to CISADA, goods imported from the US to Dubai cannot be legally exported to Iran unless they have been authorised and licensed by the US Treasury Department.

The existing sanctions allow information, humanitarian assistance, agricultural commodities, some food, medicine and goods, as well as services for commercial aircraft, the International Atomic Energy Agency (IAEA), the internet and the promotion of democracy.

No UAE firms blacklisted

He assured the audience that none of the UAE-based companies which do business with Iran have been blacklisted.

However, he stressed that the importing of refined petroleum products is prohibited under the sanctions.

Although he couldn't confirm whether companies have so far been compliant with CISADA, he said, "I think people do legitimately deserve to know where the red lines are, to avoid sanctions."

Eren advised business communities to avoid putting themselves at risk. He added, "I don't think any business in Iran is worth probing the US market floor."

He also stressed that many US companies have been over-compliant with the sanctions, but this does not apply to non-US companies.

"The law has been written in such a way that gives maximum flexibility to the US government. So you never know when they can confront. That is an environment where Iran can find itself today," he said.

While all trade in food products is exempt from the sanctions, Eren pointed out that 25,000 companies registered in the UAE and which have done business with Iran for over four decades have lost 40 per cent of their business because Iranian banks are affected by the sanctions.

Local UAE banks have stopped facilitating business activities of such enterprises and bank customers are suffering as a result, he added.

"The atmosphere about Iran is quite negative and the legal framework of CISADA is so severe. There are detailed regulations, which are very difficult to go against and it's so conditional to make the Treasury Department understand your view," he added.

Eren promised to bring up some of the issues, related to the Iran-UAE-businesses, in Washington, adding, "The law is not too efficient, but as time goes on, more issues come to the fore."