NEWSLETTER-2019-metin

386 NEWSLETTER 2019 • Activities conducted in or through the US; or • Denominated the transaction in USD. Currently, there are numerous economic sanctions programs that target countries, persons, entities, and organizations. The traditional types of economic sanctions are country-based sanctions, which pro- hibit virtually all activity and transactions involving a certain country. The US government has begun to use other kinds of sanctions, known as list-based sanctions. List-based sanctions (also known as smart sanctions), target particular persons, entities, and organizations, rather than an entire nation or regime. Country-based Sanctions The US economic sanctions regime against Iran mainly concerns country-based sanctions. Country-based sanctions function by prohibiting certain defined transactions and sometimes travel within the country’s territory, with persons who ordinarily reside within the country, and with the targeted governmental regime. Sanction programs generally prohibit trade in goods, services, technology, and financial transactions. Country-based sanctions, though broad in scope, also have general licenses that allow certain types of activity, such as the provision of le- gal services, the exchange of information and informational materials, personal communications, humanitarian aid, and journalistic projects. Nonetheless, the use of country-based sanctions has decreased with the advent of more flexible list-based programs. Some examples of currently in-force prohibitions include: • Entering into/facilitating transactions that Iran would benefit from; • Proceeding with transactions with the knowledge that a good/ service/technology is for end-use in Iran, or by an Iranian entity;