Following the implementation of the first key milestone under the Joint Comprehensive Plan of Action (“JCPOA”), the U.S. Treasury has provided guidance on the changes to U.S. sanctions against Iran.
The guidance and accompanying FAQs explain the sanctions that are no longer in force and those that remain in place as well as addressing the position for non-U.S. and U.S. persons.
Overview of the key points
1. A significant majority of U.S. primary sanctions remain in force. This includes the general embargo on trade with Iran. There remain exceptions based on case by case licensing policies on trade.
2. Non-U.S. persons are still prohibited from knowingly seeking to evade U.S. prohibitions on certain transactions and trade with Iran, including entering into arrangements or transactions with any of the individuals or entities that remain on the SDN list.
3. General License H authorizes non-U.S. entities that are owned or controlled by U.S. persons to engage in certain transactions involving Iran that were previously restricted, as long as this activity is consistent with the JCPOA.
The published guidance note can be viewed here.