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December 10, 2014

OFAC Publishes Guidance on the JPOA Involving Iran

On December 9, 2014, OFAC published notice in the Federal Register of its guidance relating to the provision of certain temporary sanctions relief in order to implement the Joint Plan of Action (“JPOA”) reached on November 24, 2013 between the P5+1 (China, France, Germany, Russia, the U.K, and the U.S.) and Iran.  The guidance was previously posted to OFAC’s website on November 25, 2014.  The JPOA was renewed on November 24, 2014 to allow the P5+1 and Iran to continue negotiations for a long-term comprehensive solution to Iran’s nuclear program.  The temporary sanctions relief period was extended to June 30, 2015.  Except for civil aviation activities and humanitarian relief, none of the sanctions relief may involve a U.S. person or foreign entity owned or controlled by a U.S. person or otherwise prohibited under any U.S. sanctions program.  Under the JPOA, the U.S. government agreed to temporarily suspend U.S. sanctions related to the following activities and associated services:

The JPOA also addressed the establishment of a financial channel to facilitate the purchase of and payment for humanitarian aid, Iran’s payments of United Nations obligations, government tuition assistance for Iranian students studying abroad, and medical expenses incurred abroad by Iranian citizens.  To implement the JPOA during the relief period, the U.S. government will not impose correspondent or payable-through account sanctions against foreign financial institutions that facilitate these transactions and will not impose blocking sanctions against non-U.S. persons not otherwise subject to sanctions regulations for specific activities related to the temporarily suspended sanctions.  The JPOA guidance is accessible here.