Maritime n Page 2 Sanctions Related to the Automotive Sector: Secondary sanctions that apply to non-U.S. persons selling, transferring, or supplying goods and services in connection with Iran’s automotive sector were lifted. Limited Relief for U.S. Persons and Entities Pursuant to the JCPOA, the United States agreed to license three categories of activity that would otherwise be prohibited, including (1) export or re-export to Iran of commercial passenger aircraft and related parts and services; (2) activities by non-U.S. persons that are owned or controlled by a U.S. person; and (3) importation of Iranian origin carpets and certain foodstuffs. However, no transactions may involve individuals or entities on the SDN List. With regard to activities by non-U.S.

persons that are owned or controlled by a U.S. person, OFAC issued General License H, which authorizes U.S.-owned or controlled foreign entities to engage in certain transactions involving Iran that would otherwise be prohibited by the Iranian Transactions and Sanctions Regulations (“ITSR”). General License H does not, however, permit U.S.-owned or controlled foreign entities to engage in activities involving:  irect or indirect exportation or re-exportation of goods,    d  technology, or services from the United States; ransfer of funds to, from, or through the U.S.

financial    t  system; ny individual or entity on the SDN List or Foreign Sanctions    a  Evaders List (“FSE List”); ctivity prohibited by, or requiring a license under, U.S.    a  Export Administration Regulations; ny military, paramilitary, intelligence, or law enforcement    a  entity of the Government of Iran, or any officials, agents, or affiliates thereof; and ertain sanctionable activity relating to proliferation of    c  weapons of mass destruction, international terrorism, Syria, Yemen, and Iran’s human rights abuses against its citizens. As a result, a number of U.S. companies are examining the possibility of permitting foreign subsidiaries to resume dealings with Iran. However, such operations would have to be undertaken without any review, approval, or other facilitation by the U.S.

parent, or any U.S.-citizen or resident employees, officers, or board members. Such constraints give rise to significant challenges with regard to governance and compliance. With regard to export to Iran of commercial passenger aircraft and related parts and services, OFAC issued a Statement of Licensing Policy establishing a licensing regime for the authorization of export, re-export, sale, lease, or transfer to Iran of commercial passenger aircraft for exclusively civil aviation use, along with spare parts, components, and services for such aircraft. Finally, with regard to importation of Iranian origin carpets and foodstuffs, OFAC issued an amendment to the ITSR authorizing the importation of Iranian origin carpets and foodstuffs, including pistachios and caviar. Conclusion and Recommendations The JCPOA Implementation Day brought significant changes to the United States’ Iran sanctions with regard to non-U.S. persons. However, with limited exceptions, the sanctions applicable to U.S.

persons remains largely unchanged. Given the complexity of the recent changes to the Iran sanctions landscape and the remaining U.S. restrictions, we recommend that any new operations involving Iran be reviewed carefully with counsel to ensure that any compliance risks are minimized. For additional information, please contact: Matthew J. Thomas 202.772.5971 | MThomas@BlankRome.com Jonathan K.

Waldron 202.772.5964 | Waldron@BlankRome.com Dana S. Merkel 202.772.5973 | DMerkel@BlankRome.com .