OFAC Offers Guidance on Dealings with Iran

By Jim Kearney

Jim Kearney

Under the Joint Comprehensive Plan of Action signed by the United States on January 16, 2016, certain nuclear-related secondary sanctions were lifted on Iran.  The partial lifting of sanctions in large measure does not apply to US companies, who continue to be broadly prohibited from engaging in transactions or dealings with Iran unless such activities are exempt or authorized by OFAC.

Under a general license issued by OFAC in January 2016, a non-US entity owned or controlled by a US person (a "US-Owned or Controlled Foreign Entity") is now authorized to engage in transactions, directly or indirectly, with the Government of Iran or any person subject to the jurisdiction of the Government of Iran even if such transaction would otherwise be prohibited if engaged in by a US person. This general license, however, does not authorize the re-exportation from a US-Owned or Controlled Foreign Entity of any US-origin goods, technology, or services.  

OFAC has now published guidance that clarifies the permissible activities of a US person who

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