I am working for a German company (in Germany) with business projects in Iran. My manager is a US citizen working in the US. He did not ask me about these projects and may not know that they even exist, but I will hold a presentation where these projects are part of the answer to his questions.

  • To what extent can I provide him information about the projects? Can I mention that we had some cash flow from Iran? Can mention the project name? Can I mention project details?
  • To what extent can he provide me with advice regarding these projects?
  • 3
    This sounds like a good question to ask your legal team. Jul 15, 2020 at 15:18
  • 1
    Are these projects covered under some ITAR regulations, or specific sanctions? For example, informing your boss that you assist humanitarian efforts in Iran would not violate sanctions. Telling him that you are helping to develop nuclear weapons would be a completely different story...
    – Ron Beyer
    Jul 15, 2020 at 15:37
  • @RonBeyer no, these are industrial projects. Thank you for that piece of information. Is he allowed to contribute to the project productively?
    – JulianG
    Jul 15, 2020 at 15:42
  • @AndrewBrēza Thank you, unfortunately they are not of any help here as there is no clear guideline, but they know that US-person are not allowed to talk with the customer and travel to the plant.
    – JulianG
    Jul 15, 2020 at 15:44
  • 5
    Without a very clear understanding of the project, the customer, the location, the end-use of the technology developed, etc, this will be impossible to answer, and even if we had that, it would be nothing more binding than an internet search. You really need to engage a specialist lawyer and sit-down with a consultation on this. Merely having your US citizen boss on the same computer network may violate international treaties. You are playing with very dangerous fire here and you need professional advice.
    – Ron Beyer
    Jul 15, 2020 at 15:56

1 Answer 1


We have no information on contractual obligations imposed on you by your employer. You may be compelled to provide information or prohibited from doing so on that basis. Conceivably there is some "compartmentalization" requirement to the effect that only certain employees are allowed access to certain information, so you'd need to ask higher-up in the company.

The company has the option of doing business in Iran, which may affect its ability to do business in the US. The company may not have the option of complying with US sanctions (I don't know the status of that move in the EU). The US Dept. of Treasury has a list of links pertaining to the Iran sanctions. From what I can determine, there is no law that imposes on US citizens a criminal or civil obligation to inform on foreign employers violating the sanctions, or to resign from such positions. On the other hand, it appears that a US person would have to wash their hands of such dealings. An example of one of the executive orders currently in force is this, which affects at least one German company. Section 1 says

All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in: any person determined by the Secretary of the Treasury, in consultation with the Secretary of State

(descriptions which basically identify anyone in mining). On the face of it, the manager is compelled to not engage in such transactions.

If the EU blocking statute is in force, the manager probably cannot comply with US law, and yet he must under US law. So I would say, this is a legally unanswerable question. I doubt that there is any provision of German law that would penalize you for telling the manager of his legal risks, but I would hire an attorney to protect myself if I were in that position.

  • I don't see how the manager's learning about a project being undertaken by another part of the company would constitute the manager's assuming any possession or control of any property or interest in property.
    – phoog
    Jul 16, 2020 at 13:16

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