The US Department of the Treasury's Office of Foreign Asset Controls (OFAC) has issued a new FAQ related to the additional sanctions against Iran in response to Iran's January 8, 2020 missile attack on Ain al-Assad air base in Iraq, where US and coalition service members are stationed. The new FAQ provides for a 90-day wind-down period for transactions covered by some of the new sanctions.
The OFAC FAQ provides a 90-day wind-down period for persons engaged in transactions covered by the sanctions for the following sectors:
The FAQ also states that any new business conducted on or after January 10, 2020 will not be considered wind-down activity and could result in sanctions even during the wind-down period. The wind-down period is scheduled to expire on April 9, 2020.