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Web Alert: US re-imposition of sanctions against Iran - revocation of General License H

03 July 2018

We have previously reported in a web alert on President Trump’s decision on 8 May 2018 to withdraw from the Joint Comprehensive Plan of Action (JCPOA) and re-impose US sanctions against Iran. 

On 27 June 2018 US OFAC announced that it has revoked General Licence H (GLH) which allowed US owned or controlled foreign entities to transact certain business with Iran pursuant to the JCPOA. On the same day it issued a general license authorising until 4 November 2018 the winding down of activities involving Iran that were previously authorised under GLH. Any activities by US owned or controlled foreign entities that continue after the winding down period concludes on 4 November 2018 may be subject to enforcement action by US OFAC. In considering what potential enforcement or sanctions actions to take with respect to activities engaged in after 4 November, US OFAC will take into account the efforts to wind down activities involving Iran prior to that date. Further details are provided on the US Treasury Dept. website.

US OFAC has also issued updated FAQs which were originally issued on 8 May 2018 regarding the US re-imposition of sanctions against Iran here

If members have any queries regarding the above please contact your usual club contact for guidance.