New OFAC regulations on Iran

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) recently made significant changes to the U.S. sanctions regulations related to Iran. On 22 October 2012, OFAC amended the Iranian Transactions Regulations (ITR), renamed the regulations to be called the Iranian Transactions and Sanctions Regulations (ITSR), and reissued the rules in their entirety. Given the nature of the changes, companies should review their global operations related to Iran in detail. Some changes resulted in the elimination of license exceptions. Other changes offer opportunities to companies by creating new general licenses for trade without the need for a specific license. Please let us know if you would like to discuss further any of these provisions.

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