Guidance: OFAC has amended its FAQ on the JCPOA nuclear deal with Iran as to what would happen if there were a “snapback” and sanctions were reintroduced (link here). The updated answers, M.4 and M.5 say:
- The US will not retroactively impose sanctions for legitimate activity undertaken after Implementation Day, but the JCPOA does not grandfather contracts signed prior to snapback.
- The US government anticipates working with US or third-country companies to minimise the impact of sanctions on legitimate activities taken prior to a snapback, and that as a general matter it would give non-US, non-Iranian persons 180 days to wind down operations entered into pursuant to the JCPOA.
General Licence J: OFAC has also amended General Licence J, which authorises the re-exportation of certain civil aircraft to Iran, to allow the temporary re-export of eligible aircraft that involve code sharing arrangements. The amended licence is here.