668. Is there a wind-down period?

Persons engaged in transactions that could be sanctioned under E.O. 13871 had a 90-day period after the issuance of E.O. 13871 to wind down those transactions without exposure to sanctions under E.O. 13871. Those persons were advised to take the necessary steps to wind down transactions by the end of the 90-day wind-down period to avoid exposure to sanctions, and that entering into new business that would be sanctionable under the E.O. on or after May 8, 2019 will not be considered wind-down activity and could be sanctioned even during the wind-down period. The wind-down period expires on August 6, 2019.