Iran Civil Aircraft Parts Transactions – Not Dead Yet!

On November 24, we reminded the community that the program permitting licenses to ship parts to Iran was expiring. Last night (November 25), that program was extended through June 30, 2015.

The program is based on a Joint Plan of Action (JPOA) reached by China, France, Germany, Russia, the U.K. and the U.S. (the P5+1) and Iran.  The JPOA is intended to help permit some trading relationships while an agreement is being negotiated, and was an inducement to encourage Iran to join the negotiations.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has published some additional guidance on this program which is specifically related to this extension:

• Temporary Sanctions Relief in Order to Implement the November 24, 2013 JPOA Between the P5+1 and Iran, as Extended Through June 30, 2015;
• Frequently Asked Questions Relating to the Extension of Temporary Sanctions Relief through June 30, 2015, to Implement the JPOA Between the P5+1 and Iran​;
• Second Amended Statement of Licensing Policy on Activities Related to the Safety Of Iran’s Civil Aviation Industry

Aircraft parts suppliers who wish to sell civil aircraft parts to Iranian purchasers are able to apply for and exercise the privileges of an export license through June 30, 2015.  This licensing authority is limited to civil aircraft parts, and excludes anything intended for military aircraft.  The licensing authority also extends to safety related inspections and repairs.

Reports suggest that there is some optimism about the US and Iran finally reaching an accord by the Spring – so now is the time to start developing relationships with Iranian customers!