On June 8, 2016, the U.S. Department of Treasury Office of Foreign Assets Con- trol (“OFAC”) issued new guidance in the form of frequently asked questions (“FAQs”) on the scope of sanctions relief available under the Joint Comprehensive Plan of Action (“JCPOA”). (See January 2016 Kirkland Alert for more details). The new FAQs address key areas of concern for U.S. companies and their affiliates, in- cluding recusal; changes to policies and procedures to permit foreign entities owned or controlled by U.S. parent companies to engage in Iran-related business that is newly authorized under General License H (“GL H”); and the extent to which a U.S. parent company may have any oversight of day-to-day business of foreign enti- ties engaging in Iran-related business. Read more.
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