The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has revoked on June 27, 2018 Iran-related General Licenses H and I, which were issued in connection with the Joint Comprehensive Plan of Action (JCPOA) respecting Iran. Due to the Trump administration’s withdrawal from the JCPOA on May 8, 2018, OFAC amended the Iranian Transactions and Sanctions Regulations (ITSR) at 31 C.F.R. Part 560 to set forth a timeline for winding down activities under both these General Licenses.
The timeline is as follows:
General License I – authorized wind-down through August 6, 2018 [Former License covered Certain Transactions Related to the Negotiation of, and Entry into, Contingent Contracts for Activities Eligible for Authorization Under the Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services]
General License H – authorized wind-down through November 4, 2018 [Former License covered Certain Transactions relating to Foreign Entities Owned or Controlled by a United States Person]
In addition, the ITSR amendments provide for the winding down through August 6, 2018 of transactions related to the importation into the United States of, and dealings in, certain foodstuffs [i.e., intended for human consumption that are classified under chapters 2–23 of the Harmonized Tariff Schedule of the United States]; and in carpets [i.e., carpets and other textile floor coverings and carpets used as wall hangings that are classified under chapter 57 or heading 9706.00.0060 of the Harmonized Tariff Schedule of the United States].
Finally, the ITSR amendments provide for the winding down through August 6, 2018 of ancillary transactions related to letters of credit and brokering services covering those same certain foodstuffs and carpets.