The United States historically has maintained both primary sanctions, prohibiting US persons from engaging in transactions relating to Iran or involving parties on the List of Specially Designated Nationals and Blocked Persons (SDN List) maintained by the US Treasury Department’s Office of Foreign Assets Control (OFAC), and secondary sanctions, which target the activities of non-US persons. Most of the relief under the JCPoA relates to nuclear-related secondary sanctions. The primary sanctions remain largely in place.
Under the JCPoA, the United States has removed sanctions directed at non-US persons with respect to certain activities. Those with particular relevance to financial institutions include financial and banking measures, insurance measures and gold and other precious metals. More information.
The US commitments to lift secondary sanctions do not apply to transactions or activities involving individuals and entities who remain or are placed on OFAC’s SDN List after Implementation Day or to any other US sanctions that may apply under legal provisions other than those cited in the JCPoA.
The United States removed over 400 individuals and entities from sanctions lists maintained by OFAC. Secondary sanctions continue to apply to non-US persons for conducting transactions with any of the more than 200 Iranian or Iran-related individuals and entities who remain or are placed on the SDN List, notwithstanding the lifting of certain secondary sanctions.
In addition, the United States implemented certain limited relief related to the primary sanctions directed at the activities of US persons, including a general license (General License H), authorizing non-US entities that are US-owned or US-controlled, with certain limitations, to engage in transactions involving Iran.
Importantly, many restrictions and/or limitations still apply post-Implementation Day. Those of particular relevance to financial institutions include primary US sanctions on Iran and limitations for non-US subsidiaries in engaging in Iran-related activities. Further information.
Further detailed guidance and FAQs have been published by OFAC.