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U.S. guidance on trade sanctions being reimposed on Iran

U.S. guidance on trade sanctions, reimposed on Iran

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today announced the following guidance concerning an executive order reimposing sanctions with respect to Iran:

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  • A list of “frequently asked questions” (FAQs) relating to the new executive order on Iran 
  • Amended existing FAQs relating to the Iran Freedom and Counter-Proliferation Act of 2012
  • A revised OFAC statement and updated existing FAQs [PDF 280 KB] relating to the president’s May 2018 decision to cease U.S. participation in the Joint Comprehensive Plan of Action (JCPOA) and to reimpose all sanctions lifted or waived in connection with the JCPOA (specifically, OFAC updated FAQ 1.4 and inserted new FAQs 2.3 - 2.7)

Today, 6 August 2018, is the last day of the 90-day wind-down of certain sanctions relief specified in the JCPOA and as set out in the FAQs.

When President Trump ended U.S. participation in the JCPOA in May 2018, it was announced that the administration would be re-imposing sanctions on the Iranian regime after two wind-down periods (90 days and 180 days) for business activities involving Iran. The first wind-down period (90 days) is ending, and the following sanctions will be re-imposed of as of 7 August 2018:

  • The purchase or acquisition of U.S. bank notes by the Government of Iran
  • Iran’s trade in gold and other precious metals
  • Graphite, aluminum, steel, coal, and software used in industrial processes
  • Transactions related to the Iranian Rial
  • Activities relating to Iran’s issuance of sovereign debt
  • Iran’s automotive sector

The 180-day or second wind-down period will conclude 4 November 2018, at which time, the following remaining sanctions will be put into place to affect:

  • Iran’s port operators and energy, shipping, and shipbuilding sectors
  • Iran’s petroleum-related transactions
  • Transactions by foreign financial institutions with the Central Bank of Iran

The United States also in November 2018 will re-list hundreds of individuals, entities, vessels, and aircraft that were previously included on sanctions lists. Since the withdrawal of the United States from the JCPOA, the administration has sanctioned 38 Iran-related targets in six separate actions.

Read Executive Order 13846 [PDF 197 KB] released today for publication in the Federal Register

 

For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner, Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

Andy Siciliano
Partner, National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Irina Vaysfeld
Principal
T: 212-872-2973
E: ivaysfeld@kpmg.com

Robert Waldrop
Principal
T: 212-954-8117 
E: rwaldrop@kpmg.com

Christopher Young
Principal
T: 312-665-3229
E: christopheryoung@kpmg.com

George Zaharatos
Principal
T: 404-222-3292
E: gzaharatos@kpmg.com

John L. McLoughlin
Principal, East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Luis (Lou) Abad
Principal, WNT
T: 212-954-3094
E: labad@kpmg.com

Amie Ahanchian
Managing Director
T: 202-533-3247
E: aahanchian@kpmg.com

Gisele Belotto
Managing Director
T: 305-913-2779
E: gbelotto@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
Managing Director
T: 612-305-5533
E: jlibby@kpmg.com

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