OFAC issues Iran sanctions “snapback” clarification

Jonathan Cross (+1 917 542 7824, jonathan.cross@hsf.com) is of Counsel and Geng Li (+1 917 542 7828, geng.li@hsf.com) is an associate with Herbert Smith Freehills in New York.

On 15 December 2016, the U.S. Office of Foreign Assets Control (OFAC) updated its Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions under the Joint Comprehensive Plan of Action (“JCPOA FAQs”), providing guidance on how sanctions would be re-imposed in case of a “snapback” of Iranian sanctions. [1] Jonathan Cross and Geng Li of Herbert Smith Freehills examine the Treasury Department’s intentions.