Gulf - Iran Situation - Initial Action Plan for Investors and Large Business - Gutovska

We issue this note to assist the investors, business, their legal and crisis teams now faced with a number of dilemmas associated with the Gulf - Iran situation.

1. Immediate Actions

Most immediate actions must be, in our opinion, directed at ensuring safety and security, to the extent possible, of those who are or might be affected on the territories now affected by the situation.

It is advisable to exercise caution and sound judgment. For example, in the situation where the commercial airlines cancelled their travel, and the government of a particular state has "closed" the sky, it is in general advisable not to use private air transportation and take relevant safe routes for evacuation, if needed. The governments of the affected states issue the directions regarding taking shelter, receiving medical assistance, etc.

It is uncertain what might be, if there is any, liability of international business for not taking care of, or taking unsufficient care of, their personnel, management teams etc now based in the region. We are monitoring the situation and will be issuing further guidance if and when necessary. We encourage you seeking advice of local lawyers and advisors on local / domestic issues and regulations regarding what are the rules on the national level regarding specific actions of the business and/or investors with regard to their human resources. On a human, moral level, we encourage all the business to take care of their teams who may be affected by the events no matter what might be the obligations on a legislative level in a particular Gulf state.

Documents and valuable items should be, if possible, removed from the affected areas.

2. Impact on Business / Contracts Performance / Litigation

It is most likely that the contract deadlines, breaches of deadlines in law, failure of perfomance etc, which occurred and were caused by the events of 28 February and 01 March 2026 would be treated as affected by force majeure ("most likely" is our preliminary view, this article is not legal advice; you should seek legal advice - contact your Gutovska & Partners lawyer) but it is, as always, advisable, to do everything possible to perform your contractual duties, if this is safe to do so. It is encouraged to seek external legal advice should your teams / internal advisors expect, or in case you alerady experience, difficulty in performing a certain contractual duty due to the situation in the Gulf.

It is advisable to contact your local teams regarding situation with litigation in the each particular state. At the moment it seems that the situation with the courts / hearings varies from state to state.

4. Investments

You should use your own judgment regarding your investments in the region. We encourage you to use advisors and counsellors but also rely on your own monitoring and understanding of the situation as it is likely that some advice of external investment advisors will be heavily caveated. Your teams should in any event (in our opinion, and this is not legal advice) contact your insurers immediately.

Review your portfolios to double check whether there is any piece which is or might be affected.

5. Analysis of Information and Control

In a fluid situation like this, we encourage you to verify information received and compare several sources, and use your own judgment. It is advisable to stay calm and composed but do the actions necessary to exercise control, to the extent possible, over your interests in the region.

We will continue to monitor the situation. Our hopes are for safety and compliance with the international law.

Olga Gutovska, Managing Partner of Gutovska & Partners, commented: "It seems that it is a serious situation and I advise to stay alert and cautious".