OFAC Amends Iranian Transactions and Sanctions Regulations

The U.S. Treasury Department Office of Foreign Assets Control ("OFAC") rescinded two general licenses that were issued in connection with the Joint Comprehensive Plan of Action ("JCPOA").

Following President Donald J. Trump's announcement that he was ending U.S. involvement in the JCPOA, OFAC rescinded General License H, which previously authorized U.S.-owned or -controlled foreign entities to engage in certain activities involving Iran; and General License I, which previously authorized certain transactions related to authorized exports or re-exports to Iran of commercial passenger aircraft and related parts and services. Under the amendments to the Iranian Transactions and Sanctions Regulations ("ITSR"), these general licenses are now replaced with two new general licenses authorizing the winding down of transactions previously authorized under the general licenses through August 6, 2018 (General License I) and through November 4, 2018 (General License H).

In addition, OFAC amended the ITSR to narrow the scope of two general licenses related to the import of Iranian-origin carpets and foodstuffs, and to authorize the wind down through August 6, 2018, of activities that were previously authorized under those general licenses.

In connection with these ITSR amendments, OFAC updated its Frequently Asked Questions 4.3, 4.4. and 4.5 under the FAQs: Re-Imposition of Sanctions pursuant to the May 8, 2018 NSPM Relating to the JCPOA.