Following Monday’s agreement between the P5+1 countries and Iran to extend for a second time the Joint Plan of Action (JPOA) for an additional seven months to enable further progress in nuclear talks, the US Treasury Department’s Office of Foreign Assets Control (OFAC) has published key documents regarding continued implementation of the temporary sanctions relief provided for under the JPOA. The latest documents essentially republish OFAC’s earlier guidance and FAQs on the sanctions easing and OFAC’s Statement of Licensing Policy on activities relating to Iran’s civil aviation industry. They reflect the continuation of the sanctions relief period through June 30, 2015, but do not change the scope of the sanctions easing, which remains limited to certain sector-specific extraterritorial sanctions. Any activities conducted during the extended JPOA relief period must still be fully completed by June 30, 2015 to qualify.
OFAC publishes guidance to reflect extension of temporary sanctions relief under Iran JPOA until 30 June 2015
By Alison J. Stafford Powell and Kathryn J. Anderson 1 Min Read
Ms Stafford Powell advises on all aspects of outbound trade compliance, including compliance planning, risk assessments, licensing, regulatory interpretations, voluntary disclosures, enforcement actions, internal investigations and audits, mergers and acquisitions and other cross-border activities. She develops compliance training, codes of conduct, compliance procedures and policies. She has particular experience in the financial services, technology/IT services, travel/hospitality, telecommunications, and manufacturing sectors.
Kathryn Anderson is an associate in Baker McKenzie's International Commercial Practice Group in San Francisco. Kathryn's practice focuses on cross-border transactions and international trade regulation, including export controls, trade and investment sanctions, anti-terrorism controls, and customs and import regulations. Her practice also covers anti-corruption rules and international corporate compliance.