OFAC issues new Iran-related Frequently Asked Question

On 16th January 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new Iran-related Frequently Asked Question (FAQ). This new FAQ covers the wind-down period pertaining to Executive Order (E.O) 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran.” Persons engaged in transactions that could be sanctioned under E.O. 13902 have 90 days to wind-down such activities (until 9th April 2020). OFAC also clarifies that “entering into new business that would be sanctionable under the E.O. on or after January 10, 2020 will not be considered wind-down activity” and therefore could be sanctionable.