OFAC advises on definition of “maintenance” in Iran general licences

OFAC has issued guidance in an FAQ on General Licence K as to which activities are considered “maintenance” in the conduct of Iran-related business. OFAC will consider past practices of parties to assess whether their conduct constitutes maintenance of a pre-existing contract / agreement. The guidance clarifies that there is no pre-existing relationship between the parties, or if the contemplated …

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About Michael O'Kane

Michael O'Kane

Michael was called to the Bar in 1992 and prior to joining Peters & Peters was a senior specialist prosecutor at the Crown Prosecution Service Headquarters (CPS). He was a key member of a small specialist unit responsible for the prosecution of serious and high-profile fraud, terrorist,...

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