“The OFAC official was very satisfied when he found what compliance program we were using.”


OFAC’s Iran Sanctions Summary

On May 8, 2018, President Trump announced that the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA) would end and following a wind-down period the U.S. would begin the re-imposition of the nuclear-related sanctions that had been lifted. At the same time, the President issued National Security Presidential Memorandum-11 which directs the U.S. Department of the Treasury and other Departments and Agencies to take steps to implement this decision.

As a result, Departments and Agencies implemented 90-day and 180-day wind-down periods for activities involving Iran that were consistent with the U.S. sanctions relief specified in the JCPOA. To facilitate the wind-down periods, the State Department has issued the necessary statutory sanctions waivers for the duration of the relevant wind-down periods. As well, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has revoked, or amended, as needed, general and specific licenses issued in connection with the JCPOA. OFAC also issued new authorizations to allow the wind down of transactions and activities that were authorized pursuant to the revoked or amended general and specific licenses.

August 6, 2018, marked the final day of the 90-day wind-down period. The President has issued Executive Order 13846 (E.O.) of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran” , which reimposes relevant provisions of five Iran sanctions E.O.s that were revoked or amended by E.O. 13716 of January 16, 2016. Executive Order 13846 came into effect at 12:01 a.m. eastern daylight time (EDT) on August 7, 2018, at which time the sanctions subject to the 90-day wind-down period came into effect pursuant to Executive Order 13846 and, as appropriate, relevant statutory provisions that are no longer within the scope of the waiver actions taken by the Secretary of State.

In addition, certain wind-down general licenses (GLs) previously issued by OFAC expired at 11:59 p.m. EDT on August 6, 2018. For detailed information regarding which GLs expired on August 6 and which sanctions were reimposed on August 7, see FAQ 1.2 of the Frequently Asked Questions Regarding the Re-Imposition of Sanctions Pursuant to the May 8, 2018 National Security Presidential Memorandum Relating to the Join Comprehensive Plan of Action (JCPOA).

The 180-day wind-down period ends at 11:59 p.m. eastern standard time (EST) on November 4, 2018, and the remaining sanctions that had been lifted or waived pursuant to the JCPOA come back into full effect on November 5, 2018. For information about which sanctions will be reimposed on November 5, 2018, see FAQ 1.3 of the Frequently Asked Questions Regarding the Re-Imposition of Sanctions Pursuant to the May 8, 2018 National Security Presidential Memorandum Relating to the JCPOA. OFAC will publish additional guidance with respect to the end of the 180-day wind-down period no later than November 4, 2018.

*Note: This information is provided for reference only and was taken from the U.S. Dept. of the Treasury’s Resource Center. For a full list of all Executive Orders, Statutes, Rules and Regulations Relating to Iran, visit the U.S. Dept. of the Treasury’s Resource Center.

Goods and Services

No goods, technology, or services may be exported, supplied, or sold, directly or indirectly by any U.S. person inside or outside the United States, to or from Iran or the Government of Iran. This includes financing export transactions with Iran, and brokering any dealings that benefit Iran or the Iranian government.

Oil and Gas

Under the current Iran sanctions, U.S. companies are not allowed involvement with petroleum development in Iran. This includes investment and trade in petroleum products from Iran and Iranian oil and gas companies, plus all petroleum and petrochemical companies identified by the U.S. Department of Treasury as being controlled by the Iranian government.

Financial Transactions

U.S. persons may not make any new investments (including loans or extensions of credit) in Iran or Iranian companies, including banks, or perform transactions or contracts with Iran. “U-Turn” transfers involving Iran, where the transfer originates and ends with non-Iranian foreign banks, are also prohibited. U.S. persons may not enter or facilitate entry to Iran. U.S. banks or their foreign branches may not service any financial accounts belonging to the Iranian government or persons in Iran.

Companies and individuals in breach of the sanctions are considered to be aiding a foreign entity hostile to the United States and its allies, and are liable to major penalties including criminal prosecution.

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