On December 26, 2012, the Office of Foreign Assets Control (OFAC) issued a final rule (ITSR Amendments) to amend the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR). The ITSR Amendments primarily implement Executive Order 13628 (Oct. 9, 2012), which, among other things, extended prohibitions applicable to transactions with Iran, the Government of Iran, and Iranian parties by “U.S. Persons” to non-US entities owned or controlled by US Persons. OFAC also added a general license to the ITSR that authorizes owned/controlled non-US entities to engage in transactions ordinarily incident and necessary to wind down Iran-related transactions between October 9, 2012 and March 8, 2013. The ITSR Amendments became effective immediately.

For discussion of who is a “U.S. person” and implications for companies engaging in transactions with Iran, please see our Client Alert: Focus on Iran: OFAC Amends Iranian Transactions and Sanctions Regulations to Implement Executive Orders 13622 and 13628 and New Wind-Down General License

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