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ARTICLE · 09 JULY 2018

U.S. Revokes Certain Authorizations Related To Iran, Issues "Wind-Down" Regulations

Holland & Knight
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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on June 27, 2018, took further concrete action to reimpose restrictions on Iran that were authorized by OFAC...

United StatesInternational Law
Jonathan Epstein
Jonathan Epstein
Ronald Oleynik
Ronald Oleynik
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Jonathan M. Epstein and Ronald A Oleynik are partners in Holland & Knight's Washington D.C. office

HIGHLIGHTS:

  • The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) revoked certain Iran-related "general licenses" that allowed U.S. and U.S.-owned foreign entities to engage in certain transactions and activities involving Iran.
  • OFAC replaced these general licenses with new regulatory general licenses allowing for the winding-down of previously authorized activities.
  • These actions follow President Donald Trump's May 8, 2018, decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA).

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on June 27, 2018, took further concrete action to reimpose restrictions on Iran that were authorized by OFAC general license during the period that the Joint Comprehensive Plan of Action (JCPOA) was in effect. (See Holland & Knight's alert, "The U.S. Will

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