JCPOA Implementation Day Guidance: Automotive Sector

G. Sanctions Related to the Automotive Sector

Commitment:

Section 4.7 of Annex II and section 17.1 of Annex V of the JCPOA provide for the lifting, on
Implementation Day, of secondary sanctions that apply to non-U.S. persons with respect to the
sale, supply, or transfer of goods or services used in connection with Iran’s automotive sector and
the provision of associated services for such activity.

Implementation:

To effectuate the lifting of these sanctions on Implementation Day, the USG, in addition to
removing certain individuals and entities from the SDN List, FSE List, and NS-ISA List as
described in section III below, took the following steps:

1. Correspondent or Payable-Through Account Sanctions:

a. Waived the imposition of correspondent or payable-through account sanctions
under: section 1245(d)(1) of NDAA 2012 (for significant financial transactions by
FFIs with the CBI)
66; section 1245(c) of IFCA (for significant financial
transactions by FFIs for the sale, supply, or transfer to or from Iran of precious
metals or specified materials (graphite, raw or semi-finished metals such as
aluminum and steel, coal, and software for integrating industrial processes) that
are within the scope of the waivers under section 1245(a)(1) of IFCA, as
described in section VI below); and section 1247(a) of IFCA.
67

b. Revoked E.O. 13645, including the correspondent or payable-through account
sanctions under subsection 3(a)(i) (for significant transactions by FFIs on behalf
of any Iranian person on the SDN List or any other person included on the SDN
List whose property and interests in property are blocked pursuant to subsection
2(a)(i) of E.O. 13645 or E.O. 13599) and subsection 3(a)(ii) (for significant
transactions by FFIs for the sale, supply, or transfer to Iran of significant goods or
services used in connection with the automotive sector of Iran).
68


c. Committed to refrain from imposing sanctions under section 561.203(a) of the
IFSR for transactions by FFIs with the CBI that are consistent with the waiver of
section 1245(d)(1) of NDAA 2012.

Blocking Sanctions:


a. Waived the imposition of blocking sanctions under section 1244(c)(1) of IFCA69
(with respect to non-U.S. persons who knowingly provide significant financial,
material, technological, or other support to, or goods or services in support of any
activity or transaction on behalf of or for the benefit of a person determined to be
part of the energy, shipping, or shipbuilding sectors of Iran or to operate a port in
Iran, or Iranian individuals or entities set forth in Attachment 3 to Annex II of the
JCPOA).
70

b. Revoked: E.O. 13622, including the blocking sanctions under section 5(a) (with
respect to persons who have materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services in support of, NIOC,
NICO, or the CBI, or the purchase or acquisition of U.S. bank notes or precious
metals by the Government of Iran); and E.O. 13645, including the blocking
sanctions under subsection 2(a)(i) (with respect to persons who have materially
assisted, sponsored, or provided financial, material, or technological support for,
or goods or services to or in support of, any Iranian person included on the SDN
List or any other person included on the SDN List whose property and interests in
property are blocked pursuant to subsection 2(a)(i) of E.O. 13645 or E.O.
13599).
71


Menu-based Sanctions:

a. Waived the imposition of menu-based sanctions under: sections 1245(a)(1)(B),
1245(a)(1)(C)(i)(II), and 1245(a)(1)(C)(ii)(II) of IFCA (with respect to non-U.S.
persons who sell, supply, or transfer to or from Iran specified materials (graphite,
raw or semi-finished metals such as aluminum and steel, coal, and software for
integrating industrial processes), subject to certain limitations as described in
section VI below); and section 1246(a) of IFCA72 (for non-U.S. persons who
provide underwriting services, insurance, or reinsurance in connection with
activities involving Iran that are described in sections 17.1 to 17.2 and 17.5 of
Annex V of the JCPOA, or to or for any individual or entity whose property and
interests in property are blocked solely pursuant to E.O. 13599).

b. Revoked E.O. 13645, including the menu-based sanctions under section 5 (for
non-U.S. persons engaging in significant transactions for the sale, supply, or
transfer to Iran of significant goods or services used in connection with the
automotive sector of Iran).

See section III for an overview of the sanctions list removals that occurred on Implementation
Day and section VI for an overview of the waiver determinations and findings issued in
connection with the JCPOA.

Effects of the lifting of sanctions related to the automotive sector:

As a result of the lifting of sanctions specified in section 4.7 of Annex II and section 17.1 of
Annex V of the JCPOA and described in this section, beginning on Implementation Day such
sanctions, including sanctions on associated services, do not apply to non-U.S. persons who
conduct or facilitate financial or other transactions for the sale, supply, or transfer to Iran of
goods and services used in connection with the automotive sector of Iran.

For additional information on the sanctions lifting related to Iran’s automotive sector discussed
in this subsection, please see section H of the
JCPOA FAQs.

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