OFAC amends the Cuban Assets Control Regulations to ease Cuban sanctions in response to President Obama's policy changes announced on December 17, 2014. These revisions have major implications for the banking and financial services sector. OFAC and the United Nations levy sanctions against North Korea for its missile testing exercises. Additional, the European Council continues to impose sanctions against Russia and encourages other countries to sanction the country for its annexation of Crimea and disruptive activities in eastern Ukraine.

Included in this Quarter's Sanctions Round-Up:

  • OFAC amendments to the Cuban Assets Control Regulations ease sanctions on financial services, commerce and trade and travel;
  • The Council of the European Union continues sanctions against Russia for its activities in eastern Ukraine;
  • OFAC and the United Nations issue sanctions against North Korea for its ballistic missile exercises;
  • US authorities continue to enforce sanctions through settlements;
  • Other notable developments.

Iran Nuclear Deal

On February 19, the United States government cleared The Boeing Company to begin talks with approved Iranian airline carriers regarding their flight needs, a first step toward entering the country's resurgent aircraft market. Boeing has been noticeably absent from the re-opening of Iran's aviation market, skipping a January aviation gathering in Tehran. The company cited US sanctions regulations and licensing requirements as the cause of their hesitance, stating "[w]e understand that the situation in the region is complicated and ever changing and we will continue to follow the US government's guidance." Boeing hopes that its entrance into the Iranian market will revive its stock which dropped more than 20 percent in 2016. On March 24, OFAC issued General License I titled "authorizing certain transactions related to the negotiation of, and entry into, contingent contracts for activities eligible for authorization under the Statement of Licensing Policy for activities related to the export or re-export to Iran of commercial passenger aircraft and related parts and services." This general license authorizes US persons to enter into all transactions incident to contracts for commercial passenger aircraft and related parts and services to Iran. However, all contracts must be made expressly contingent upon an issuance of a specific license by OFAC. OFAC also published four FAQs related to the new general license.

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