OFAC Warns Firms to "Wind Down" Certain Transactions with Iran

OFAC issued an FAQ concerning the wind-down period for activities that are sanctionable under Executive Order 13902 ("Imposing Sanctions with Respect to Additional Sectors of Iran").

Pursuant to FAQ 816, non-U.S. companies, financial institutions and others have a 90-day period during which to wind down transactions that would otherwise expose them to sanctions under E.O. 13902 (i.e., dealings connected to the construction, mining, manufacturing and textile sectors of the Iranian economy). OFAC urged all such persons to take the steps necessary to wind down transactions in order to avoid exposure to sanctions, and warned that engaging in any new business after January 10, 2020 would not be considered "wind-down activity" and could result in the imposition of sanctions. OFAC noted that the wind-down period expires on April 9, 2020.