In this edition:

- Implementation of the Joint Plan of Action with Iran

- Additional US Iran-Related Sanctions and Licenses

- OFAC Civil Settlements

- US and EU Sanctions in Response to the Situation in Ukraine

- US Drug- and Terror-Related Sanctions

- Suspension and Amendment of Certain EU Sanctions

- Excerpt from Implementation of the Joint Plan of Action with Iran:

US and EU Implement Temporary Sanctions Relief under Joint Plan of Action -

On January 20, following verification by the International Atomic Energy Agency that Iran had undertaken its initial commitments under the interim Joint Plan of Action, the United States and the European Union took steps to provide Iran with limited and targeted sanctions relief for an initial six-month period. In accordance with the agreement announced in November 2013, Iran has, at least for now, suspended enrichment of its most advanced uranium fuel along with other sensitive elements of its nuclear program. In return, the United States has paused its efforts to further reduce Iranian crude oil exports and will allow the six current customers of Iranian oil to maintain their purchases at current reduced levels for the duration of the six-month period. Secondary sanctions on non-US persons engaged in transactions related to Iran’s petrochemical exports, certain trade in gold and precious metals, and the provision of goods and services to Iran’s automotive sector have been suspended.1 The US will also grant licenses for transactions involving goods and services related to the safety in the Iranian aviation sector. OFAC has published guidance on the specific sanctions relief granted under the JPA, including answers to frequently asked questions and a statement of licensing policy on activities related to Iran’s civil aviation industry. Notably, OFAC has emphasized that it will continue to fully enforce all sanctions that have not been explicitly suspended, and US persons and their foreign subsidiaries remain prohibited from carrying out transactions with Iran.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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