person owns or controls any automated and globally integrated computer, accounting, email, telecommunications, or other business support system, platform, database, application, or server necessary to store, collect, transmit, generate, or otherwise process documents or information related to transactions authorized in paragraph (a) of this section.
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(2) Activities to make available to those foreign entities that the U.S. (1) Activities related to the establishment or alteration of operating policies and procedures of a United States entity or a U.S.-owned or -controlled foreign entity, to the extent necessary to allow a U.S.-owned or -controlled foreign entity to engage in transactions authorized in paragraph (a) of this section and eastern standard time on November 4, 2018: A United States person engaging in the following: (b) All transactions and activities that are ordinarily incident and necessary to the wind down of the following activities are authorized through 11:59 p.m. eastern standard time on November 4, 2018: an entity owned or controlled by a United States person and established or maintained outside the United States (a “U.S.- owned or -controlled foreign entity”) engaging in transactions, directly or indirectly, with the Government of Iran or any person subject to the jurisdiction of the Government of Iran that would otherwise be prohibited by § 560.215. (a) Except as provided in paragraph (c) of this section, all transactions and activities that are ordinarily incident and necessary to the wind down of the following activities are authorized through 11:59 p.m. § 560.537 Winding down of transactions relating to foreign entities owned or controlled by a U.S. subsidiaries to take advantage of General License H should consult § 560.537, and the guidance published by OFAC.įor your convenience, we reproduce ITSR § 560.537 below. U.S.-based companies that had modified policies and procedures to enable their non-U.S. 4, 2018, all transactions and activities that are ordinarily incident and necessary to the wind-down of transactions relating to foreign entities owned or controlled by a United States person that were previously authorized under General License H.Īn archival version of General License H remains posted on OFAC’s website to aid persons in determining which activities were not sanctionable or prohibited while the authorization was in effect and how best to wind down such activity. OFAC has added § 560.537 to the Iranian Transactions and Sanctions Regulations (ITSR) to authorize through 11:59 p.m. parents no longer required General License H. companies will be subject to sanctions if they engage in many types of Iran-related transactions after a wind-down period, non-U.S. OFAC presumably concluded that, just as non-U.S. secondary sanctions will “ snap back” into effect. On June 27, OFAC revoked General License H pursuant to the United States’ withdrawal from the JCPOA. financial system from those transactions. parents to engage in many Iran-related transactions, provided that those foreign subsidiaries excluded U.S. General License H was designed to level the playing field – it authorized foreign subsidiaries of U.S. In contrast, the United States maintained nearly all of its “primary” sanctions preventing U.S.-based companies from engaging in trade with Iran, and those sanctions normally extend to foreign subsidiaries of U.S. companies that had engaged in Iran-related transactions.
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The United States suspended its “secondary” sanctions that had targeted European and other non-U.S. At that time, the European Union removed many of the sanctions that had prevented European-based companies from engaging in trade with Iran. As we reported in January 2016, the Office of Foreign Assets Control (OFAC) published General License H in conjunction with the implementation of the Joint Comprehensive Plan of Action (JCPOA).