On December 15, 2016, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) updated the Frequently Asked Questions Relating to the Lifting of Certain US Sanctions Under the Joint Comprehensive Plan of Action. Update to Joint Comprehensive Plan of Action FAQs In this regard, Secretary of State Kerry issued a statement on the same day as the White House to announce that the US State Department will renew ISA-related waivers under the JCPOA.

The Obama Administration emphasized that it has used, and continues to use, necessary authorities to waive relevant sanctions, enforce those sanctions that are outside of the scope of the JCPOA, and re-impose sanctions if necessary in the event that Iran should fail to meet its commitments under the JCPOA. The White House issued a statement on Decemthat affirms this understanding, stating in relevant part that an extension of the ISA, while unnecessary, is consistent with the US Government’s commitments under the JCPOA. The extension of the ISA’s terms does not change the state of current US primary or secondary sanctions targeting Iran. 6297 does not impose new sanctions targeting Iran and does not affect other US sanctions measures such as those under the Iranian Transactions and Sanctions Regulations and the Export Administration Regulations. Most of its provisions have been suspended under the Joint Comprehensive Plan of Action (“JCPOA”). The Iran Sanctions Act (“ISA”) is one of the primary US statutes that provides legal authority for US secondary sanctions (i.e., sanctions primarily targeting non-US companies engaging in certain Iran-related activities) targeting Iran.

It became law without President Obama’s signature. 6297 was approved by the House of Representatives in a 419-1 vote and by the Senate in a 99-0 vote. 6297) went into effect and extended the Iran Sanctions Act of 1996 (“H.R. On December 15, 2016, the Iran Sanctions Extension Act (H.R.

Ofac iran sanctions act