OFAC Amends the Iranian Transactions and Sanctions Regulations

/ Global Compliance Solutions Group LLC/

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).  

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