I. Sanctions Related to Iran’s Export of
Petrochemical Products
The JPOA provides for the temporary suspension of
U.S. sanctions on “Iran’s petrochemical exports, as well as sanctions on
any associated services.” To implement this provision of the JPOA, the USG
will take the following steps to allow for the export of petrochemical products
from Iran, as well as associated services, by non-U.S. persons not otherwise
subject to section 560.215 of the Iranian Transactions and Sanctions
Regulations, 31 C.F.R. part 560 (ITSR), (hereinafter “non-U.S. persons not
otherwise subject to the ITSR”):
1. Correspondent or Payable-Through
Account Sanctions: The USG will not impose correspondent or
payable-through account sanctions under section 1(a)(iii) of Executive Order (E.O.)
13622 (as amended by section 16(b) of E.O. 13645); section 3(a)(i) of E.O.
13645; and sections 561.204(a) and 561.204(b)(3) of the Iranian Financial
Sanctions Regulations, 31 C.F.R. part 561 (IFSR), on foreign financial
institutions that conduct or facilitate transactions that are initiated and
completed entirely within the JPOA Period by non-U.S. persons not otherwise
subject to the ITSR for exports of petrochemical products2 from Iran that are initiated and completed
entirely within the JPOA Period, including transactions involving the
petrochemical companies listed in the Annex to this guidance, provided that the
transactions do not involve persons on the SDN List other than the
petrochemical companies listed in the Annex to this guidance or any Iranian
depository institutions3 listed solely pursuant to E.O. 13599.