Alerts and Updates

OFAC Revokes Iran-Related General Licenses H and I

July 6, 2018

OFAC added a new general license to authorize the wind down of certain transactions relating to foreign entities owned or controlled by a United States person.

In a June 28, 2018, Notice in the Federal Register, the Office of Foreign Assets Control (OFAC) announced that it has revoked Iran-related General Licenses H and I, which were issued in connection with the Joint Comprehensive Plan of Action (JCPOA). OFAC took these actions in furtherance of President Trump’s May 8, 2018, decision to withdraw from the JCPOA and to begin reimposing the U.S. nuclear-related sanctions that had been suspended to effectuate the JCPOA sanctions relief. The revocations are effective June 27, 2018, but OFAC has issued new licenses that allow a wind-down period.     

As noted in our previous Alert, President Trump instructed that General License H be revoked. This license permitted an entity owned or controlled by a United States person and established or maintained outside the United States to engage in transactions with the Government of Iran or persons subject to the jurisdiction of the Government of Iran. In the absence of General License H, such transactions would have been a violation of U.S. law. In its place, OFAC added a new general license to authorize the wind down, through November 4, 2018, of certain transactions relating to foreign entities owned or controlled by a United States person.

OFAC also revoked General License I, which authorized certain transactions related to the negotiation of, and entry into, contingent contracts for transactions for the sale of commercial passenger aircraft and related parts and services to Iran under the under the Statement of Licensing Policy for Activities Related to the Export or Reexport to Iran of Commercial Passenger Aircraft and Related Parts and Services (SLP). In its place, OFAC added a new general license to authorize the wind down, through August 6, 2018, of transactions related to the negotiation of contingent contracts for activities eligible for authorization under the SLP. 

In addition, OFAC amended the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), in order to narrow the scope of the general licenses authorizing the importation into the United States of, and dealings in, Iranian-origin carpets and foodstuffs, as well as related letters of credit and brokering services, to the wind down of such activities through August 6, 2018.

For More Information

If you would like further information about this Alert, please contact Hersh Kozlov of the Iran Sanctions Practice 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.