President Trump today announced his decision to begin re-imposing nuclear-related sanctions with respect to Iran, following a “wind-down” period. The president also directed the U.S. Treasury Department and State Department to take actions necessary to implement his decision.
As noted in a Treasury release, the Treasury Department and State Department will begin the process of implementing 90-day and 180-day wind-down periods for activities involving Iran. To effectuate the wind-down periods, the State Department issued certain statutory sanctions waivers to provide for a wind-down period and plans to take appropriate action to keep such waivers in place for the duration of the relevant wind-down periods. As soon as is administratively feasible, Treasury’s Office of Foreign Assets Control (OFAC) expects to revoke, or amend, as appropriate, general and specific licenses and to issue new authorizations to allow the wind-down of transactions and activities that were authorized pursuant to the revoked or amended general and specific licenses. At the end of the 90-day and 180-day wind-down periods, the applicable sanctions will come back into full effect.
OFAC today posted a list of “frequently asked questions” (FAQs) [PDF 63 KB] that provide guidance on the sanctions that are to be re-imposed and the relevant wind-down periods.
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