It is important to note that the embargo against Iran remains in place and that U.S. persons, unless licensed or otherwise authorized by OFAC (often also requiring a determination by the U.S. Department of Commerce, Bureau of Industry and Security, of EAR 99 status) are prohibited.
On July 14, 2015, the United States Department of the Treasury's Office of Foreign Assets Control (OFAC) announced that although the United States and other negotiating parties reached an agreement under the Joint Comprehensive Plan of Action (JCPOA) with the goal of ensuring that Iran's nuclear program will be exclusively peaceful, sanctions will remain in place until the International Atomic Energy Agency verifies that Iran has implemented key nuclear-related measures described in the JCPOA. This date will be known as Implementation Day.
OFAC states that until Implementation Day, all specific licenses that were issued pursuant to OFAC's Second Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry and have an expiration date on or before July 14, 2015, are authorized to remain in effect according to their terms.
It is important to note that the embargo against Iran remains in place and that U.S. persons, unless licensed or otherwise authorized by OFAC [often also requiring a determination by the U.S. Department of Commerce, Bureau of Industry and Security, of EAR 99 (Export Administration Regulations) status] are prohibited.
For Further Information
If you would like more information about this Alert, please contact Brian S. Goldstein, any member of the International Practice Group or the attorney in the firm with whom you are regularly in contact.
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