Since we last spoke of "Implementation Day" established on January 16 under the Joint Comprehensive Plan of Action (see "Implementation Day" Brings Openings for Commercial Aircraft Sales With Iran advisory from January 22), the state of US sanctions programs targeting Iran in the commercial passenger aircraft industry has continued to evolve. One recent action, US Treasury Department's Office of Foreign Assets Control's (OFAC) General License I issued on March 24, should allow US persons to more easily enter into contingent contracts, negotiations and transactions incident to the entry into contracts for the sale of aircraft or related parts to Iran.
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