On June 27, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it was amending the Iranian Transactions and Sanctions Regulations (“ITSR”) to revoke or narrow certain general licenses issued as part of the US sanctions relief implementing the Joint Comprehensive Plan of Action (“JCPOA”), replacing them with more limited wind-down authorizations. Importantly, OFAC stated that these actions were in furtherance of President Trump’s May 8, 2018 decision to withdraw the United States from the JCPOA. As discussed in our earlier blog post, OFAC had previously announced its intent to replace these general licenses with more limited wind-down authorizations in public guidance issued on May 8, 2018, which OFAC updated in connection with these changes.
Executive Summary Effective May 8, 2018, the US Government withdrew from the Joint Comprehensive Plan of Action (“JCPOA”). The US Government will re-instate the sanctions that were lifted or waived following the implementation of the JCPOA. This action has a greater impact on non-US persons because most of the lifted or waived sanctions were secondary sanctions targeting activities of non-US companies occurring outside of US jurisdiction. The sanctions will be re-instated on August 7,…