OFAC Completes Reimposition of Iran Sanctions Following 180-Day 'Wind-Down'
The Office of Foreign Assets Control on Nov. 5 issued a final rule implementing the “snap back” of its Iran sanctions regulations following the U.S. decision to withdraw from the Joint Comprehensive Plan of Action in May (see 1805080056). The…
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agency is also re-adding more than 700 persons to its Specially Designated Nationals list that had been removed as a result of the now-defunct Iran nuclear deal. The actions come at the end of a 180-day “wind-down” period of phased reimplementation of the Iran sanctions, with many provisions on trade having already come into effect in August. This final phase mostly affects Iranian shipping, petroleum and financial institutions. OFAC also updated its frequently asked questions document on the Iran sanctions with new information related to the return of sanctions, including on provisions related to payments for goods or services already provided before sanctions were reinstated.