§560.536 – Winding down of transactions related to the negotiation of 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.persons acting as brokers for the purchase or sale of the permitted Iranian-origin goods provided that the goods are not for exportation or supply, direct/indirectly, to Iran, the Government of Iran, an Iranian financial institution, or any blocked persons. financial institutions issuing, advising, negotiating, or confirming letters of credit to pay for transactions related to Iranian-origin goods from the Government of Iran, an Iranian financial institution, or any blocked persons. financial institutions issuing letters of credit in favor of a beneficiary in Iran, the Government of Iran, Iranian financial institutions, or any blocked persons. – All transaction ordinarily incident and necessary to the wind-down of the following activities are authorized through 11:59PM ET on August 6, 2018: §560.535 – Winding down of transactions related to letters of credit and brokering services relating to certain foodstuffs and carpets.– All transaction ordinarily incident and necessary to the wind-down of the following activities are authorized through 11:59PM ET on August 6, 2018: The importation of Iranian origin goods including foodstuffs intended for human consumption and carpets/textiles. §560.534 – Winding down of transactions related to the importation into the United States of, and dealings in, certain foodstuffs and carpets.

OFAC amended the Iranian Transactions and Sanctions Regulations (“ITSR”) to implement the President’s May 8th, 2018 decision to withdraw from the JCPOA, as outlined in the National Security Presidential Memorandum (“NSPM”): Anyone engaging in any activities which are contrary to the current sanctions laws could be liable for such activities. Wind-down of Iran-related activities pursuant to authorizations provided by the JCPOA is required in the next 90 or 180 days depending on the nature of the transaction. Wind-down of JCPOA Related Activity and the Re-imposition of SanctionsĪll of the sanctions in existence prior to the JCPOA including nuclear-related secondary sanctions will be in effect on November 5, 2018.

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