This month the U.S. Treasury Department's Office of Foreign
Assets Control (OFAC) updated its 'Frequently Asked Questions
Relating to the Lifting of Certain U.S. Sanctions Under the Joint
Comprehensive Plan of Action (JCPOA) on Implementation Day'
(FAQs). While the updated FAQs do not contain any new measures that
ease sanctions against Iran, they do provide some much needed
clarity, which is likely to have a positive impact on business
transactions with Iran.
U.S. Dollar Payments
One of the more consequential pieces of guidance OFAC added to
the FAQs is its clarification on the extent to which payments for
authorised transactions can be made in U.S. dollars. OFAC made
clear that foreign financial institutions (FFIs) (including foreign
incorporated subsidiaries, but not branches, of U.S. financial
institutions) are permitted to "process transactions
denominated in U.S. dollars or maintain U.S. dollar-denominated
accounts that involve Iran or persons ordinarily
