Because of the US sanctions, there are many limitations and restrictions on some countries, and these sanctions also affect the people of those countries.

Suppose that a person, A, was going to work with a company in the Netherlands which in 2019 was acquired by an American company. Recently the company told A that because the company belongs to an American company, they can not proceed and get A the work permit, but they also said if A were in the Netherlands now, it would be easier.

  1. Is there any way this company can hire A while A is still in Iran?

  2. How can they hire A if A were in the Netherlands? (For instance as a traveler in the Netherlands)

  3. If they can hire A while a/he is in the Netherlands, could they also hire A if A were in Turkey?

1 Answer 1


It's difficult to tell: it's possible that you could be hired, or that you can't be hired. The easy part, the third question, is that this is not a ban based on ethnicity or citizenship, it is based no residence, so it you are not in Iran, you're not a target of the ban.

The sanctions prohibit the importation of certain services of Iranian origin (e.g. employment), and also §560.419 says that

The prohibitions in §560.201 make it unlawful to hire an Iranian national ordinarily resident in Iran to come to the United States solely or for the principal purpose of engaging in employment on behalf of an entity in Iran or as the employee of a U.S. person, unless authorized pursuant to § 560.505. See also § 560.418 with respect to the release of technology and software.

But you are not coming to the US (or The Netherlands). Nevertheless, HR of the employing firm may have misinterpreted the regulation.

There is a good chance that you would not be subject to the importation of services regulation, §560.201:

Except as otherwise authorized pursuant to this part, and notwithstanding any contract entered into or any license or permit granted prior to May 7, 1995, the importation into the United States of any goods or services of Iranian origin or owned or controlled by the Government of Iran, other than information and informational materials within the meaning of section 203(b)(3) of the International Emergency Economic Powers Act (50 U.S.C. 1702(b)(3)), is prohibited.

First, is there a reasonable interpretation of the circumstances where your services are imported into the US? Second, is the hiring company a subsidiary of a US firm and is controlled by the US firm (if not, the US sanctions do not apply to a foreign employer). Under the Iran Threat Reduction and Syrian Human Rights Act §218, that would be

(1) one that is more than 50% owned by the U.S. parent; (2) one in which the parent firm holds a majority on the Board of Directors of the subsidiary; or (3) one in which the parent firm directs the operations of the subsidiary.

The nature of the services imported also matters: information services can be imported, likewise sports-related services. Importation of oil and gas related services is prohibited. So all told, it's difficult to say what is allowed in this circumstance.

  • Does it matter how the American company holds the Dutch company - as a subsidiary or as a somewhat arms length shareholder ? Commented Sep 27, 2021 at 20:55

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