Yesterday’s action also revokes OFAC’s general licenses authorizing imports into the United States of Iranian-origin carpets and foodstuffs and the entry into contingent contracts related to sales of commercial passenger aircraft and related goods and services, which have been replaced with similar wind down provisions requiring that all such activity cease by August 7, 2018. In its place, OFAC has issued a new general license authorizing the wind down of business with Iran by foreign subsidiaries until November 5, 2018. The most significant change is the revocation of OFAC’s General License H, which had provided sanctions relief pursuant to the JCPOA for foreign subsidiaries of US companies conducting business with Iran. Yesterday’s action primarily impacts certain US companies, as well as non-US companies owned or controlled by US persons. In addition, OFAC updated its Frequently Asked Questions (FAQs) providing guidance on the JCPOA withdrawal, although these minor updates do not add much insight. Effective yesterday, as part of the President’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the Office of Foreign Assets Control (OFAC) revoked several general authorizations that had been issued as part of the JCPOA, and amended the Iranian Transactions and Sanctions Regulations (ITSR) to implement “wind down” periods for persons who had previously relied on these authorizations.
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