US – OFAC and State issue guidance relating to certain temporary Iran sanctions relief – extended

On August 4, 2014, the Office of Foreign assets Control (OFAC), Treasury, published in the Federal Register a notice publishing Guidance Relating to the Provision of Certain Temporary Sanctions Relief in Order to Implement the Joint Plan Of Action (JPOA) Reached on November 24, 2013, between the P5 + 1 and the Islamic Republic of Iran, as Extended Through November 24, 2014 (Guidance).

In return for Iran’s commitment to place meaningful limits on its nuclear program, the P5 + 1 (China, France, Germany, Russia, the United Kingdom, and the United States, coordinated by the European Union’s High Representative) committed to provide Iran with limited, targeted, and reversible sanctions relief for a six-month period, renewable by mutual consent. In furtherance of the United States Government’s (USG’s) commitments under the JPOA, the US Department of State and the US Department of the Treasury implemented sanctions relief relating to certain activities and associated services taking place exclusively during the sixmonth period beginning on January 20, 2014, and ending July 20, 2014 (the JPOA Period).

The JPOA was renewed by mutual consent of the P5 + 1 and Iran on July 19, 2014, extending the temporary sanctions relief provided under the JPOA to cover the period beginning on July 21, 2014, and ending November 24, 2014 (the Extended JPOA Period), in order to continue to negotiate a long term comprehensive solution to ensure that Iran’s nuclear program will be exclusively peaceful. During the Extended JPOA Period, the sanctions relief the USG committed to during the JPOA will be continued, as set out in the Guidance. The USG retains the authority to revoke this limited sanctions relief at any time if Iran fails to meet its commitments under the JPOA.

The Department of State and the Department of the Treasury jointly issued the updated Guidance on July 21, 2014. At the time of its issuance on July 21, 2014, OFAC made the Guidance available on the OFAC Web site and the Department of State made the Guidance available on its Web site. With the notice, OFAC is publishing the Guidance in the Federal Register.

The effective date of the Guidance was July 21, 2014.
On the same date, the Department of State published in the Federal Register a notice [Public Notice 8809] outlining the US government actions taken to implement the sanctions relief aspects of the understanding with Iran, outlined in the Joint Plan of Action (JPOA), as extended, that halts progress on its nuclear program and rolls it back in key respects. The effective dates of these waiver actions are as described in the determinations set forth in the State notice.