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August 18, 2016

OFAC Publishes Iran-Related General License J

On July 29, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published General License J authorizing the reexportation by non-U.S. persons of “eligible aircraft” (and a narrow scope of related equipment and technology) to Iran on temporary sojourn, provided that specific requirements are met.

“Eligible Aircraft”

“Eligible aircraft” here means U.S. origin fixed-wing civil aircraft (or non-U.S.-origin fixed-wing civil aircraft of which U.S.-controlled content constitutes 10 percent or more of the total value) that is classified under ECCN 9A991.b. Additionally, in order for an aircraft to be considered an “eligible aircraft” it must not be registered in the U.S. or in a country listed in Country Group E:1 (Cuba, Iran, North Korea, Sudan, and Syria). Other criteria that deal with the operational control of the aircraft, among other requirements, also must be satisfied in order for a non-U.S. person to use the authorization in General License J.

Onboard Supplies

General License J also authorizes non-U.S. persons to reexport to Iran “usual and reasonable quantities of industry standard onboard supplies of civil aircraft equipment, spare parts, components, and technology for permanent use on the Eligible Aircraft,” provided that:

Technology for Emergency Maintenance and/or Repairs

Lastly, General License J authorizes non-U.S. persons to reexport to Iran technology for purposes of emergency maintenance on and/or repairs to an Eligible Aircraft, provided that:

If you have specific questions regarding General License J, please feel free to contact us.

[1] Transactions related to non-emergency and/or line maintenance in Iran of Eligible Aircraft reexported to Iran on temporary sojourn is not authorized by General License J and requires a separate OFAC authorization.