OFAC Issues New Iran Sanctions FAQ Announcing 90-Day Wind-Down Period | Practical Law

OFAC Issues New Iran Sanctions FAQ Announcing 90-Day Wind-Down Period | Practical Law

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.

OFAC Issues New Iran Sanctions FAQ Announcing 90-Day Wind-Down Period

Practical Law Legal Update w-023-6981 (Approx. 3 pages)

OFAC Issues New Iran Sanctions FAQ Announcing 90-Day Wind-Down Period

by Practical Law Commercial Transactions
Published on 21 Jan 2020USA (National/Federal)
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.
On January 16, 2020, the US Department of the Treasury's Office of Foreign Asset Controls (OFAC) issued a new FAQ that provides for a 90-day wind-down period for transactions covered by sanctions against Iran that were issued on January 10, 2020, and covered in E.O. 13902 (85 Fed. Reg. 2003). For more information on the new sanctions, see Legal Update, US Imposes Additional Sanctions Against Iran in Response to Missile Attack.
The OFAC FAQ provides a 90-day wind-down period for persons engaged in transactions covered by the sanctions for the following sectors:
  • Construction.
  • Mining.
  • Manufacturing.
  • Textiles.
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.
For an overview of economic and trade sanctions administered by OFAC, see Practice Note, Export Regulation: OFAC Economic and Trade Sanctions.