Newsflash: News about Iran?


Cologne, 5th August 2018


The Office of Foreign Assets Control (OFAC) has issued a regulation amending the Iranian Transactions and Sanctions Regulations (ITSR), which will enter into force with its announcement in the Federal Register on 5 November 2018.

Despite the intense media coverage given to this Amendment, in terms of substance it contains nothing new. The Amending Regulation essentially implements the decision reached by the US President on 8 May 2018 on the withdrawal from the Joint Comprehensive Plan of Action (JCPOA) (see Newsflash dated 29 June 2018) and matters already applicable today on grounds of the subsequent Executive Order 13846 as well as the sanction lists issued by the OFAC.

The primary purpose of the Amending Regulation is, therefore, to uniformly integrate the applicable regulations into the ITSR and it depicts the end of the wind-down period that commenced in May. The wind-down period permitted the completion of ongoing business. From today on, such residual wind-down business is no longer permissible either.  

A link to further information can be found HERE.

Stephan Müller


Telephone: +49 221 2091 448
Telefax: +49 221 2091 333

Denmark, Finland, Israel, Norway, Sweden

Mareike Heesing

Attorney, Associate

Telephone: +49 221 2091 320
Telefax: +49 221 2091 333