Day 18 of Signature’s Slide Show series – How do US sanctions against Iran fit in French international public policy?

By Signature Litigation
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Signature Litigation

The Paris Court of Appeal’s decision of 3 June 2020 clarifies how United States sanctions fit in French international public policy.

The Court explained that foreign overriding mandatory rules were a part of international public policy only if “they carry values and principles which may not be breached according to French public policy, even in an international context”.

Please note that this does not mean US sanctions will never apply in disputes linked to France. US sanctions may apply with respect to the lex contractus or the subject matter of the dispute. However, deciding the scrutiny they require or determining whether they should apply is not a question for the annulment judge but for the arbitral tribunal.

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