Iran Sanctions Look to Snap Back

By now you’ve heard the news, and it’s pretty much what it sounds like.

Following a wind-down period of 90 or 180 days, the U.S. government will restore the economic sanctions that it lifted under the 2015 nuclear deal. These sanctions generally affect foreign businesses who do business with Iran. After the wind-down periods, they can no longer do so without risking civil or criminal penalties.

In the meantime, here are some answers from the Treasury Department. Can you transact new business during the wind-down periods? It doesn’t say outright that you can’t, but the government will hold that against you if you blow the deadline. What if you take steps to wind down now but are still owed money after the 90 or 180 days? In a nutshell, you may continue to collect on a contract as long as you entered into it before May 8.

The 90-day period ends August 6, after which the U.S. will restore sanctions on the following:

1. Selling or providing U.S. dollars to the Iranian government.
2. Trading with Iran in gold or precious metals.
3. Trading with Iran, directly or indirectly, in coal, steel, graphite, aluminum, other metals, and software for related industrial processes.
4. Significant transactions to buy or sell Iran’s currency or significant funds or accounts denominated in it.
5. Buying, subscribing to, helping issue the Iranian government’s debt.
6. Iran’s automotive sector.

The end of the 90-day period will also revoke permission for the U.S. itself to do business with Iran in two ways: by importing Iranian carpets and foodstuffs and by exporting commercial passenger aircraft and related parts and services on a select basis.

The 180-day period ends November 4, after which the U.S. will restore sanctions on the following:

1. Iran’s ports as well as its shipping and shipbuilding sectors.
2. Buying oil and related products from Iran.
3. Transactions by foreign banks with the Central Bank of Iran and other Iranian financial institutions.
4. Providing insurance, reinsurance, or other underwriting services.
5. Iran’s energy sector.
6. Specific people and entities that had been removed from the U.S. list of blocked persons and interests.

The end of the 180-day period will also revoke permission for American-owned businesses located abroad to do business with Iran.

Stay tuned for more developments as the dust settles.