united-states sanctions
To what extent can I inform my US Manager about projects in Iran
<p>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.</p>
<ul>
<li>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?</li>
<li>To what extent can he provide me with advice regarding these projects?</li>
</ul>

<p>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 &quot;compartmentalization&quot; 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.</p>
<p>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 <a href="https://www.dw.com/en/eu-to-reactivate-blocking-statute-against-us-sanctions-on-iran-for-european-firms/a-43826992" rel="nofollow noreferrer">that move</a> in the EU). The US Dept. of Treasury has a <a href="https://www.treasury.gov/resource-center/sanctions/programs/pages/iran.aspx" rel="nofollow noreferrer">list of links</a> 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 <a href="https://www.treasury.gov/resource-center/sanctions/Programs/Documents/13871.pdf" rel="nofollow noreferrer">is this</a>, which affects at least one German company. Section 1 says</p>
<blockquote>
<p>All  property  and  interests  in  property  that  are  in  the
United  States,  that  hereafter  come  within  the  United  States,
<em>or  that  are  or  hereafter  come  within  the  possession  or  control  of  any  United  States  person</em>  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</p>
</blockquote>
<p>(descriptions which basically identify anyone in mining). On the face of it, the manager is compelled to not engage in such transactions.</p>
<p>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.</p>
