US Revokes Iran Sanctions General Licenses H and I
Treasury's OFAC revoked general licenses that permitted foreign subsidiaries of US companies to transact with Iran and authorized contingent aircraft-sale talks, implementing the US JCPOA withdrawal.
Implementing the administration's May 2018 withdrawal from the Joint Comprehensive Plan of Action (JCPOA), the US Treasury's Office of Foreign Assets Control (OFAC) has revoked two key general licenses authorizing certain Iran-related transactions. The revocations, effective June 27, 2018, eliminate General License H, which had permitted foreign entities owned or controlled by US persons to do business with Iran. This materially alters compliance obligations for US multinationals, whose foreign subsidiaries must end all US-jurisdiction-touching Iran activities. OFAC also revoked General License I, which authorized contingent contract negotiations for commercial passenger aircraft sales to Iran. To manage the transition, OFAC issued replacement wind-down licenses. Activities previously authorized under GL-H must conclude by November 4, 2018; aircraft-related negotiations and certain Iranian imports (carpets, foodstuffs) must wind down by August 6, 2018. Sophisticated counsel and clients care because secondary-sanctions exposure, foreign-investment restrictions, and aviation-sector deal pipelines are all directly affected. Next to watch: completion of the wind-down periods and any further OFAC FAQ or enforcement guidance.