Implementation Day, which took place in January of 2016, resulted in some changes to U.S. sanctions law that do impact U.S. persons and entities. More specifically, the U.S. government took the following steps:

• issued a statement of favorable licensing policy regarding the export, reexport, sale, lease or transfer of commercial passenger aircraft and related parts and services to Iran for exclusively civil, commercial passenger aviation end-use;

• issued a general license authorizing non-U.S. entities that are owned or controlled by a U.S. person (“U.S.-owned or -controlled foreign entities”) to engage in activities hat are consistent with the JCPOA and applicable U.S. laws and regulations; and

• issued a general license authorizing the importation into the United States of Iranian-origin carpets and foodstuffs, including pistachios and caviar.

Outside of the changes outlined above, all of the other changes involved NON-U.S. persons and entities. Therefore U.S. persons and U.S. companies continue to be broadly prohibited from engaging in transactions or dealings with Iran and the Government of Iran unless such activities are exempt from regulation or authorized by OFAC. The majority of the sanctions lifted on Implementation Day DO NOT apply to U.S. persons and entities. Therefore U.S. persons and U.S. companies continue to be broadly prohibited from engaging in transactions or dealings with Iran and the Government of Iran unless such activities are exempt from regulation or authorized by OFAC.

Before engaging in any type of transaction with Iran, US persons (meaning any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States) must still ensure that that comply with the US sanctions and regulations. For more information contact our firm today.