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Publication of Iran sanction-related Frequently Asked Questions

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OFAC updated the Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action, amending one FAQs related to Snapback Mechanism (M.4) and adding one FAQ related to Wind-down Period (M.5). According to para. M.4 “in the event of a snapback, sanctions will not apply retroactively to legitimate business activity that takes place after Implementation Day but before the snapback occurs”. Moreover, pursuant to para M.5 in the event of a JCPOA sanctions snapback, the U.S. government would provide non-U.S., non-Iranian persons a 180-day period to wind down operations in or business involving Iran that was consistent with the U.S. sanctions lifting under the JCPOA and undertaken pursuant to a written contract or written agreement entered into prior to snapback”. These FAQs can be accessed here.


keywords : JCPOA , OFAC , Sanctions , Snapback Mechanism , Wind-Down Period ,