OFAC advises on wind down period for new Iran E.O.

Last week (10 January), the US signed into law Executive Order 13902 which provided for sanctions against the construction, mining, manufacturing, and textiles sectors of the Iranian economy. A new OFAC FAQ clarifies that those engaged in transactions with respect to these 4 sectors have 90 days from the issuance of the E.O. to wind down transactions (until 9 April …