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July 17, 2018

OFAC Revokes JCPOA General Licenses and Amends ITSR

By: Lindsey Roskopf

In order to help implement the President’s May 8, 2018 decision to withdraw from the Iran nuclear deal (also known as the Joint Comprehensive Plan of Action or JCPOA) and to begin re-imposing the U.S. nuclear-related sanctions that were lifted to effectuate the JCPOA sanctions relief, following a wind-down period, on June 27, 2018, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), officially revoked Iran-related General Licenses H (authorization for U.S.-owned or –controlled foreign entities) and I (statement of licensing policy for commercial aircraft).  In their place, OFAC issued two new general licenses authorizing the wind down, through August 6, 2018, of transactions previously authorized under General License I, and the wind down, through November 4, 2018, of transactions previously authorized under General License H.  Prior to August 6, 2018, or November 4, 2018, as applicable, entities engaging in activity consistent with the U.S. sanctions relief specified in the JCPOA should use these new general licenses to take the steps necessary to wind down operations by that date to avoid exposure to sanctions or an enforcement action when the applicable wind-down period ends. 

In addition, OFAC amended the Iranian Transactions and Sanctions Regulations in order to narrow the scope of the general licenses authorizing the importation into the United States of, and dealings in, Iranian-origin carpets and foodstuffs, as well as related letters of credit and brokering services.  The general license now only permits the wind down of such activities through August 6, 2018. 

OFAC also updated its FAQs regarding the reimposition of the sanctions.