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State Dept. Provides Limited and Temporary Iranian Sanctions Relief

Wednesday, December 31, 2014
Sandler, Travis & Rosenberg Trade Report

The Department of State has announced that the U.S. will provide certain limited and temporary sanctions relief in order to implement the Nov. 24, 2013 Joint Plan of Action between the P5+1 (the U.S., Russia, China, the United Kingdom and France, plus Germany) and Iran, as extended through June 30, 2015. Among other actions, State is temporarily waiving the imposition of sanctions pursuant to Section 1244(c)(1) of the Iran Freedom and Counter-Proliferation Act of 2012 to the extent required for:

- transactions by non-U.S. persons for the export from Iran of petrochemical products and for associated services, excluding any transactions involving persons on the list of specially designated nationals and blocked persons of the Office of Foreign Assets Control (except for certain companies);

- transactions by U.S. or non-U.S. persons for the supply and installation of spare parts necessary for the safety of flight for Iranian civil aviation, for safety-related inspections and repairs in Iran and for associated services, provided that OFAC has issued any required licenses, excluding any transactions involving persons on the SDN List (except for Iran Air);

- transactions by non-U.S. persons to which sanctions would not apply if an exception under Section 1244(g)(2) of IFCA were applied to China, India, Japan, Korea, Taiwan and Turkey, and for insurance and transportation services associated with such transactions, provided that such transactions are consistent with the purchase amounts provided for in the JPOA and excluding any transactions or associated services involving persons on the SDN List (except for the National Iranian Oil Company and the National Iranian Tanker Company); and

- transactions by non-U.S. persons for the sale, supply or transfer to or from Iran of precious metals, provided that such transactions are within the scope of the waiver of Sections 1245(a)(1)(A) and 1245(c) of IFCA, and for associated services, excluding any transactions involving persons on the SDN List (except for any political subdivision, agency or instrumentality of the government of Iran listed solely pursuant to E.O. 13599).

State indicates that these and other waivers outlined in its Dec. 30 notice will take effect upon their transmittal to Congress, unless otherwise provided in the relevant provision of law. All suspended sanctions are scheduled to resume on July 1, 2015 unless further action is taken by the P5+1 and Iran and subsequent waivers and guidance are issued by the U.S. government. State notes that companies engaging in activities covered by the temporary sanctions relief should expect sanctions to apply to any activities that extend beyond the current end date of the extended JPOA period.

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