Advocate General Gerard Hogan of the European Court of Justice ruled on Wednesday 12 May in case C-124/20 between Bank Melli Iran and Telekom Deutschland that an EU company’s decision to terminate a contractual relationship with an Iranian company subject to US primary sanctions should be considered invalid if it could not be justified on any grounds other than the desire to comply with US law, which falls within the scope of the Union’s blocking statute.
US law provides for secondary...