On July 14, the P5 +1 countries (United States, United Kingdom, China, Russia, France and Germany) and Iran agreed on a Joint Comprehensive Plan of Action (JCPOA) to ensure that Iran’s nuclear program would be peaceful. As part of the agreement, the parties have agreed to sanctions relief which will come in phases and be based on successful implementation of nuclear commitments outlined in the deal. Iran must first implement key measures before any sanctions will be lifted. This will be a gradual process once the plan is finalized.
Exporters should expect all current sanctions to remain in place through early 2016. The Iranian Transactions and Sanctions Regulations (ITSR), which affect most transactions by U.S. persons – as well as non-U.S. persons/entities controlled by U.S. persons – will not be affected by the JCPOA. These sanctions will remain in place.
However, the U.S. has agreed to issues licenses to non-U.S. entities owned or controlled by U.S. persons to engage in some activities outlined in the JCPOA. Perhaps the most significant change is the agreement by the U.S. to allow the sale of commercial passenger aircraft and related parts to Iran, as well as the import of Iranian-origin carpets and foodstuffs. These transactions will still require a license and have not yet been implemented by the Treasury Department’s Office of Foreign Assets Control (OFAC).
Exporters can view the current Iranian sanctions and stay current on the progress of the agreement by visiting this page on OFAC’s website. As these changes unfold, it’s important to continue practicing due diligence when it comes to Iran … and if questions arise, contact an expert.
Emmalie Armstrong is a Trade Compliance Consultant with Export Solutions – a firm specializing in U.S. import/export regulations.