In what may be a harbinger of things to come, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) has issued new guidance regarding what may occur if the United States re-implements economic sanctions against Iran that were scaled back following the July 2015 nuclear deal (the Joint Comprehensive Plan of Action or JCPOA). That guidance, in the form of two amended Frequently Asked Questions (M.4 and M.5, available here), makes clear that:
- the United States will not retroactively impose sanctions for legitimate activity undertaken prior to any sanctions snapback;
- continuation of previously legitimate activities following snapback could be penalized; and
- the U.S. government intends to provide a 180-day period to wind down Iran business that was consistent with the lifting of U.S. sanctions under the JCPOA.
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