The U.S. Treasury Department’s Office of Foreign Assets Control has released a series of documents on the extension of nuclear talks between Iran and the world’s six major powers. On November 24, the two sides agreed to continue to implement the Joint Plan of Action (JPOA). As part of the agreement, Washington has extended the sanctions relief provided in the interim deal through June 30, 2015. The following are excerpts from the Treasury’s frequently asked questions document on the extension with links to its other guides.
1. Q: What types of sanctions relief will be provided to Iran pursuant to the JPOA during the JPOA Relief Period?
The USG has committed to suspend temporarily certain sanctions involving Iran’s purchase and sale of gold and other precious metals, Iran’s export of petrochemical products, Iran’s automotive industry, and certain associated services regarding each of the foregoing. The USG will also coordinate with Iran regarding the use of financial channels established in furtherance of the JPOA to facilitate Iran’s import of certain humanitarian goods to Iran, payment of medical expenses incurred by Iranians abroad, payments of Iran’s UN obligations, and payments of $400 million in governmental tuition assistance for Iranian students studying abroad. The USG will issue a favorable licensing policy in furtherance of the JPOA in connection with transactions related to the safety of Iran’s civil aviation industry. Finally, during the JPOA Relief Period, the USG will pause efforts to further reduce Iran’s crude oil exports and will enable Iran to access an agreed amount of Restricted Funds in installments. Unless otherwise noted, these relief measures do not include transactions with persons on the U.S. Treasury Department’s Office of Foreign Assets Control’s (OFAC) List of Specially Designated Nationals and Blocked Persons (the SDN List) (http://www.treasury.gov/resource-center/sanctions/SDNList/Pages/default…).
The USG will continue to vigorously enforce our sanctions against Iran that are not subject to the limited relief provided pursuant to the JPOA, including by taking action against those who seek to evade or circumvent our sanctions. The USG also retains the authority to revoke this limited sanctions relief at any time if Iran fails to meet its commitments under the JPOA.
2. Q: How do the JPOA and the extension of relief impact U.S. sanctions on Iran?
Except for the limited, temporary, and reversible relief provided pursuant to the JPOA, all U.S. sanctions with respect to Iran, including financial sanctions, sanctions pertaining to the purchase of Iranian crude oil, and sanctions on investment in Iran’s energy and petrochemical sectors, remain in effect with respect to U.S. and non-U.S. persons. The relief provided in the JPOA only pertains to conduct and transactions fully completed during the JPOA Relief Period, and, with limited exceptions, involves only certain sanctions on non-U.S. persons not otherwise subject to section 560.215 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR) (hereinafter “non-U.S. persons not otherwise subject to the ITSR”), as described in more detail in these FAQs. U.S. persons and U.S.-owned or -controlled foreign entities continue to be generally prohibited from conducting transactions with Iran, including any transactions of the types permitted pursuant to the JPOA, unless licensed to do so by OFAC.
For additional details regarding the steps taken by the USG to implement the temporary sanctions relief with respect to Iran pursuant to the JPOA, see the November 25, 2014 Guidance Relating to the Provision of Certain Temporary Sanctions Relief.
3. Q: Are U.S. persons able to engage in any of the transactions with Iran outlined in the JPOA?
U.S. persons and U.S.-owned or -controlled foreign entities continue to be generally prohibited from conducting transactions with Iran, including any transactions of the types permitted pursuant to the JPOA, unless licensed to do so by OFAC. This prohibition includes any associated services undertaken in conjunction with activities outlined in the JPOA. Except under limited circumstances such as for humanitarian transactions, the USG has a policy of not authorizing business with Iran. For additional information regarding the licensing of transactions related to the safety of flight for Iranian civil aviation see Question 10 below. U.S. persons and U.S.-owned or -controlled foreign entities may continue to engage in generally or specifically licensed humanitarian-related transactions.
Click here for Guidance Relating to the Provision Of Certain Temporary Sanctions Relief in Order to Implement the Joint Plan of Action Reached On November 24, 2013 Between The P5+1 and The Islamic Republic Of Iran, as Extended Through June 30, 2015
Click here for Frequently Asked Questions Relating to the Extension of Temporary Sanctions Relief through June 30, 2015, to Implement the Joint Plan of Action between the P5 + 1 and the Islamic Republic of Iran;
Click here for Second Amended Statement of Licensing Policy on Activities Related to the Safety Of Iran's Civil Aviation Industry