On Thursday, June 28 the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) amended (1) the Iranian Transactions and Sanctions Regulations (2) in order to implement the President's May 8, 2018 decision (3) to end U.S. participation in the Joint Comprehensive Plan of Action (JCPOA). The changes include, but are not limited to:
- Amending the general licenses authorizing the importation into the US (4) of and dealings in, Iranian-origin carpets and foodstuffs, as well as related letters of credit and brokering services, to narrow the scope of the licenses and to allow for the wind down of these activities through August 6, 2018;
- Adding a new general license to authorize the wind down, through August 6, 2018, of transactions related to the negotiation of contingent contracts for activities, previously approved under General License I (5), related to the export or re-export to Iran of commercial passenger aircraft and related parts and services; and
- Adding a new general license (6) to authorize the wind down, through November 4, 2018 of certain transactions, previously approved under General License H (7), related to foreign entities owned or controlled by a US Person (8).
- Non-US entities that are owned or controlled by a US Person are still subject to the restrictions on US Person involvement during the wind down period (9).
For more information contact your GCSG experts.
- (1) Federal Register / Vol. 83, No. 125 / Thursday, June 28, 2018 pp. 30335-30338 - Iranian Transactions and Sanctions - Final Rule
- (2) 31 CFR 560 - Iranian Transactions and Sanctions Regulations
- (3) Presidential Memoranda - "Ceasing US Participation in the JCPOA and Taking Additional Action to Counter Iran's Malign Influence and Deny Iran All Paths to a Nuclear Weapon" - 5/8/18
- (4) 31 CFR 560.534 and 560.535
- (5) General License I
- (6) 31 CFR 560.537
- (7) General License H
- (8) US Person - "the term United States person or US person means any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States." 31 CFR 560.314.
- (9) "Guidance on the provision of certain services relating to the requirements of US sanctions laws" - 1/12/17
- FAQ - "Regarding the Re-Imposition of Sanctions Pursuant to the May 8, 2018 National Security Presidential Memorandum Relating to the JCPOA" - 5/8/18; updated 6/27/18
- Office of Foreign Assets Control
- US Department of the Treasury
- US Department of State
- US Department of State - Press Release "Senior State Department Official On U.S. Efforts to Discuss the Re-imposition of Sanctions on Iran With Partners Around the World" - June 26, 2018