Business With Iran – Grinding to a Halt?

Several ASA members have looked into doing business with Iranian air carriers and other Iranian customers.  Some have even applied for export licenses to support such business.  But those efforts appear to be wasted as the US prepares to begin enforcing sanctions against Iran, once again.

Today (May 8, 2018), the President announced his decision to discontinue the United States’ participation in the Agreement with Iran, and to reimpose sanctions against Iran.

The Treasury has published a Frequently Asked Questions document explaining the upcoming process for Iranian sanctions.  The FAQ, consistent with the President’s announcement, requires the Secretaries of State and of the Treasury to take immediate steps to re-impose all United States sanctions lifted or waived in connection with the JCPOA, including those under the National Defense Authorization Act for Fiscal Year 2012, the Iran Sanctions Act of 1996, the Iran Threat Reduction and Syria Human Rights Act of 2012, and the Iran Freedom and Counter-proliferation Act of 2012.  These steps shall be accomplished as expeditiously as possible, and in no case later than 180 days from May 8, 2018.

As part of this process, the U.S. government plans to revoke JCPOA-related authorizations such as the aircraft and aircraft parts-related licenses issued pursuant to the US-Iran Agreement; expect to see these permits terminated as of August 6, 2018,

Applicants whose pending license applications are denied may resubmit their applications for consideration under the safety of flight statement of licensing policy found in 31 C.F.R. § 560.528. That provision permits licenses on a case-by-case basis for exporting to Iran in order to ensure the safety of civil aviation and safe operation of U.S.-origin commercial passenger aircraft.

About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

2 Responses to Business With Iran – Grinding to a Halt?

  1. Peter Lewis says:

    ASA Members may also want to consider re-locating to a country with a sane leadership.

  2. Pingback: Doing Business With Iran Under a JCPOA License? Get Your Transactions Completed by August 6, 2018. | ASA Web Log

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