persons had been significantly and negatively affected based on the US Government’s “maximum pressure” campaign against the Government of Iran.įirst, as previously advised, on September 20, 2019, OFAC designated the CBI as a Specially Designated National and Blocked Person (SDN) under the Global Terrorist Sanctions Regulations (GTSR). 8, humanitarian trade from the United States and involving U.S. 8 and other measures taken by the US Government should now facilitate transfers, transactions, and certain activities related to the exportation and reexportation of agricultural commodities, medicines, and medical devices to Iran.
Until OFAC issues guidance on the breadth of activities allowed under the temporary authorizations, companies attempting to wind-down business in Iran would be advised to take a conservative approach with robust compliance efforts.Effective February 27, 2020, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury issued General License (GL) Number 8 to authorize certain humanitarian transactions involving the Central Bank of Iran (CBI). However, it remains unclear at this time what the scope of permissible wind-down activities would cover. The temporary authorizations provided in §§ 560.534-560.537 generally mirror the authorizations in the JCPOA-related general licenses, except the authorized activities are limited to “transactions and activities that are ordinarily incident and necessary to the wind down” of the previously authorized activities. The temporary authorizations pertaining to General License I and Iranian carpets and foodstuffs will expire at 11:59 p.m. eastern standard time on November 4, 2018. The temporary authorizations pertaining to General License H will expire at 11:59 p.m.
OFAC also amended its JCPOA-related FAQs 4.3, 4.4, and 4.5, issued on May 8, 2018, to reference these temporary wind-down authorizations. Specifically, OFAC is amending §§ 560.534 and 560.535 (relating to Iranian-origin carpets and foodstuffs), and creating new sections 560.536 (relating to activities under General License I) and 560.537 (relating to activities under General License H).
OFAC is contemporaneously revising the Iranian Transactions and Sanctions Regulations (“ITSR”) to provide temporary authorizations to wind-down the activities previously permitted by the JCPOA-related general licenses. §§ 560.534 and 560.535, which authorized the importation of Iranian-origin carpets and foodstuffs, as well as related credit and brokering services.