829. Following the Secretary of State’s announcement on May 27, 2020 that he will be ending certain Iran nuclear-related waivers, will there be a wind-down period for persons engaged in activity permitted by these waivers?

Yes.  Persons engaged in activities currently permitted by the Department of State’s nuclear-related waivers associated with the Arak reactor modernization redesign, the transfer into Iran of enriched uranium for the Tehran Research Reactor, and the transfer out of Iran of certain nuclear fuel scrap and of spent research reactor fuel will have a final, 60-day wind-down period in which to cease these activities without risking exposure to covered sanctions.  The 60-day wind-down period ends on July 27, 2020.  Persons engaged in such activities should take the steps necessary to wind down those activities by July 27, 2020 to avoid potential exposure to sanctions under U.S. law. Persons engaged in such activities after that date may be exposed to certain sanctions under the Iran Freedom and Counter-Proliferation Act (IFCA) absent a waiver or exception.  IFCA provides for sanctions on persons determined to knowingly provide significant financial, material, technological, or other support to, or goods or services in support of any activity or transaction on behalf of or for the benefit of, an Iranian person on OFAC’s SDN List, such as the Atomic Energy Organization of Iran (AEOI).  IFCA also provides for sanctions on persons determined to knowingly sell, supply, or transfer, directly or indirectly, to or from Iran certain materials, including raw and semi-finished metals, if the materials are provided to or from an Iranian person on OFAC’s SDN List, such as AEOI.  For more information, please see the Department of State's Website.  [05-27-2020]