State and Local Divestment Measures: A Growing U.S. Trade Compliance Concern

In recent years, a growing number of U.S. state and local governments have adopted divestment measures targeting companies doing business or investing in Iran and Sudan, among other countries. These divestment measures typically prohibit governmental entities from investing in or contracting with certain listed companies. Because federal sanctions already prohibit U.S. companies from engaging in virtually all transactions involving Iran or Sudan, the primary targets of such measures have been non-U.S. companies. The consequences of such divestment actions for non-U.S. companies include reputational risks and subsequent divestment actions, making it important for non-U.S. companies to remain vigilant about divestment-related inquiries ...