Three More Days: Licenses to Sell Aircraft Parts to Iran are Extended Again

Since November 24, 2013, the United States operated under a Joint Plan Of Action (JPOA) with Iran that has permitted the export of commercial aircraft parts to Iran (when licensed by the US Treasury Department’s Office of Foreign Asset Control). That authority was set to run out on June 30, 2015, and was extended by a week through July 7.  No agreement has been reached so the authority has been extended for three more days, to July 10, 2015.

The parties to the Iran talks have decided to extend the JPOA for three more days in order to continue negotiations. This means that the existing authority is extended through July 10, 2015.

As always, please look carefully at your license language to ascertain whether it is extended with the JPOA extension. The Announcement from the Treasury Department states that:

Effective July 1, 2015, all specific licenses that:
(1) were issued pursuant to OFAC’s Second Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry, and
(2) have an expiration date of July 7, 2015, or earlier are hereby authorized to remain in effect according to their terms through July 10, 2015.

The last license extension was more specific, the or earlier language means that a broader range of licenses may be extended (including some that were not extended for the past week).  This is good news for those have licenses issued under the Second Amended Statement of Licensing Policy.

While this extension is better drafted, the fact that it is only three days long may make it practically impossible for distributors to take advantage of it, unless they have existing relationships that allow them to accept purchase orders, full fill them, and get paid by the end of the week.

One hopes that the next extension, if it happens, would be more commercially reasonable and would permit a longer period for the extension in order to permit U.S. industry to solicit orders and fulfill them.

 

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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