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845. Will there be a wind-down period for non-U.S. persons engaged in previously non-sanctionable activity involving the Iranian financial sector or Iranian financial institutions (FIs) that are now sanctioned pursuant to E.O. 13902?


Yes.  Non-U.S. persons engaged in transactions and activities involving the Iranian financial sector or any Iranian FI sanctioned pursuant to E.O. 13902 that were not previously sanctionable will have 45 days to conclude these activities without risking exposure to sanctions.  The 45-day wind-down period ends on November 22, 2020.  Non-U.S. persons engaged in certain activities involving Iranian FIs sanctioned under E.O. 13902 after that date may be exposed to sanctions.  OFAC continues to analyze whether select types of transactions and activities may, nonetheless, be non-significant and, thus, not sanctionable even after the end of the wind-down period.  OFAC anticipates issuing additional guidance regarding the scope of transactions and activity by non-U.S. persons that will become sanctionable after November 22, 2020.  

Note that, even after the wind-down period, non-U.S. persons do not risk exposure to sanctions for engaging in humanitarian-related transactions or activities, including conducting or facilitating a transaction for the provision (including any sale) of agricultural commodities, food, medicine, and medical devices to Iran, with Iranian FIs sanctioned pursuant to E.O. 13902.  In addition, GL L authorizes under E.O. 13902 those transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 that are authorized, exempt, or otherwise not prohibited under the Iranian Transactions and Sanctions Regulations.  For more information, please see FAQs 842 and 844.

Date Released
October 8, 2020