OFAC's published guidance and frequently asked questions ("FAQs") regarding the U.S. government's JCPOA sanctions relief can be found at the following link: https://www.treasury.gov/resourcecenter/sanctions/Programs/pages/iran.aspx. __________________________________________ [1] Under the JCPOA, the U.S. agreed to remove from the SDN List many - but not all - Iranian persons that had been designated as SDNs as part of the U.S. nuclear sanctions against Iran.

Iranian persons listed for reason of antiterrorism, violation of human rights, or proliferation of weapons of mass destruction, or destabilizing activities with respect to Syria or Yemen, remain subject to sanctions. Indeed, just one day after Implementation Day OFAC added a number of Iranian persons to the SDN List for activities associated with Iran's ballistic missiles program. For more information, please contact: F. Amanda DeBusk, Partner +1 (202) 721-4790 amanda.debusk@hugheshubbard.com Melissa Duffy, Partner +1 (202) 721-4689 melissa.duffy@hugheshubbard.com Alan Kashdan, Counsel +1 (202) 721-4689 alan.kashdan@hugheshubbard.com International Trade and Customs January 2016 Hughes Hubbard & Reed LLP A New York Limited Liability Partnership | One Battery Park Plaza New York, New York 10004-1482 | +1 212-837-6000 Attorney advertising.

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