Sanctions 17 Jan, 2020 Iran sanctions - Wind-down period announced for recent measures Tony Paulson Head of Asia & Corporate Director Further to our News Item of 13 January 2020, OFAC have now issued a FAQ related to the new sanctions against Iran which provides for a 90-day period – i.e. until 9 April 2020 - for parties to wind down their activities related to the construction, mining, manufacturing, and textiles sectors of the Iranian economy. It will be recalled that these new measures were introduced as a result of an Executive Order (E.O. 13902) issued by President Trump on 10 January 2020. Download PDF The FAQ reads as follows: “Persons engaged in transactions that could be sanctioned under E.O. 13902 with respect to the construction, mining, manufacturing, and textiles sectors of the Iranian economy have a 90-day period after the issuance of E.O. 13902 to wind down those transactions without exposure to sanctions under E.O. 13902. Such persons should take the necessary steps to wind down transactions by the end of the 90-day wind-down period to avoid exposure to sanctions, and be aware that entering into new business that would be sanctionable under the E.O. on or after January 10, 2020 will not be considered wind-down activity and could be sanctioned even during the wind-down period. The wind-down period with respect to the construction, mining, manufacturing, and textiles sectors expires on April 9, 2020.” Our U.S. attorneys Freehill Hogan & Mahar have commented that whilst the FAQ is not specific, based on other relevant FAQs the following are suggested: 1) Wind-down activities will be permitted for contracts that were in place as of 10 January 2020 (when the EO was issued), provided all goods or services are fully provided by the expiration of the wind-down period (9 April 2020). Thus, if a ship is already fixed to carry cargo to or from Iran which might implicate these new sanctions, the ship should be permitted to complete that contract provided