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Alerts and Updates

New Sectors Added to Iran Sanctions, OFAC Gives 90-Day Wind-Down Period

January 16, 2020

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The wind-down period began on January 10, 2020, and ends on April 9, 2020.

Pursuant to Executive Order 13902 of January 10, 2020, which was published in the Federal Register on January 14, 2020 (85 Fed. Reg. 2003), President Donald Trump has imposed additional sanctions against Iran’s economy. In doing so, the president stated, “It remains the policy of the United States to deny Iran all paths to a nuclear weapon and intercontinental ballistic missiles, and to counter the totality of Iran’s malign influence in the region.” He further stated that “it is the policy of the United States to deny the Iranian government revenues, including revenues derived from the export of products from key sectors of Iran’s economy… that may be used to fund and support its nuclear program, missile development, terrorism and terrorist proxy networks.”

E.O. 13902 has expanded the scope of the various sectors of the Iranian economy that are subject to sanctions imposed by the Office of Foreign Assets Control (OFAC) by including construction, mining, manufacturing or textile sectors. In addition, the E.O. provides authority for the addition of “any other sector of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State.”  

While no wind-down provisions were set forth in E.O. 13902, on January 16, 2020, OFAC published a new FAQ (816) that sets forth OFAC’s wind-down policy. The wind down authorizes a 90-day period for persons engaged in transactions that would otherwise violate E.O. 13902 to end that business. The wind-down period began on January 10, 2020, and ends on April 9, 2020, unless extended. Please note that the wind-down period does not include new business that would be subject to sanctions under E.O. 13902 on or after January 10, 2020.

For More Information

If you would like further information about this Alert, please contact Brian S. Goldstein, Geoffrey M. Goodale, J. Manly Parks, any member of the International Practice Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.