US issues Iran general licence for aircraft

OFAC has issued a new general licence, General Licence I (link here), which authorises transactions ordinarily incident to the negotiation of and entry into contracts for the export or re-export to Iran of commercial passenger aircraft or related parts and services covered by the Statement of Licensing Policy (pursuant to the JCPOA), provided that the performance of the contract is made contingent on receipt of an OFAC licence.  The general licence doesn’t not authorise transactions with blocked property.

Prior to the issuance of the general licence, US persons were required to apply to OFAC for a licence to enter into negotiations relating to contracts covered by the Licensing Policy, and then apply for a second licence to actually export the goods if a contract was formed.  The general licence is intended to ease the burden of applications received by OFAC, and so reduce processing delays, by eliminating the need to apply for a licence to negotiate authorised contracts.

This entry was posted in Iran, USA by Maya Lester QC. Bookmark the permalink.

About Maya Lester QC

Maya Lester QC has a wide ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. As the most recent (2016) Chambers & Partners directory put it, she "owns the world of sanctions". She spent 2011-12 in New York at Columbia Law School lecturing and writing on sanctions. She represents and advises hundreds of companies and individuals before the European and English courts and has acted in most of the leading cases, including Kadi, Tay Za, Central Bank of Iran, NITC and IRISL.

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