OFAC Clarifies Wind-Down Period for Iran EO, Sanctions

The Treasury’s Office of Foreign Assets Control clarified that people and companies involved in recently sanctioned Iranian sectors have a 90-day wind-down period, according to a frequently asked question issued Jan. 16. The wind-down period pertains to the sanctions and executive order recently announced by the Trump administration that authorizes new measures against the country’s construction, mining, manufacturing, and textiles sectors (see 2001100050). Entering into new business that would be considered sanctionable under the executive order after Jan. 10 will not be considered wind-down activity, the FAQ says. That activity may be subject to sanctions “even during the wind-down period.” The wind-down period expires April 9.