635. Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period under an OFAC wind-down authorization and pursuant to a contract entered into prior to May 8, 2018?

The wind-down authorizations allow U.S. persons and U.S.-owned or -controlled foreign entities to receive payments for activities conducted pursuant to such wind-down authorizations only during their validity periods. For example, a U.S.-owned or -controlled foreign entity may receive payment through 11:59 p.m. eastern standard time on November 4, 2018 for Iran-related activities undertaken pursuant to section 560.537 of the Iranian Transactions and Sanctions Regulations (ITSR) (winding down of transactions relating to U.S.-owned or -controlled foreign entities).
Any payment following the end of the relevant wind-down period for activities undertaken pursuant to a wind-down authorization, including from an Iranian counterparty, would require specific authorization from OFAC. OFAC will evaluate such requests for specific licenses on a case-by-case basis.
Any request for a specific license should provide sufficient details for OFAC to evaluate the application, including: whether the relevant transactions complied with U.S. sanctions as in effect at the time of the transactions; whether the activities were performed under a written contract or written agreement entered into prior to May 8, 2018; and why the applicant was unable to receive the payment for which authorization is sought prior to the end of the relevant wind-down period. OFAC will generally deny requests to receive payment for activities that were not authorized under the relevant wind-down authorizations or that were not undertaken pursuant to a written contract or written agreement entered into prior to May 8, 2018.
As required by 31 C.F.R. section 501.801(b), applicants should identify the names of all parties who are concerned with or interested in the proposed transaction. To facilitate OFAC’s review, the request should also include a description of the efforts that were undertaken to collect the payment during the relevant wind-down period and be accompanied by supporting documentation, including relevant contracts, invoices, and shipping documents. OFAC encourages applicants to submit applications online using OFAC's licensing application portal.