UPDATE ON IRAN AND CUBA SANCTIONS
October 2, 2015
Ongoing diplomatic efforts between the United States and Cuba and Iran are likely to continue to impact aviation regulatory matters. Details of recent developments with Iran and Cuba are below.
Cuba: The U.S. Departments of Treasury and Commerce issued new regulations on September 21, 2015 regarding Cuba in a continued push to loosen the sanctions regime against that country. The most relevant update concerns the Department of Commerce’s amended rule on the export and re-export of items related to aviation safety. Under the rule, Commerce will consider export license applications that relate to items intended to ensure the safety of Cuban civil aviation. Items that will be reviewed pursuant to this policy include aircraft parts and components related to safety of flight, weather observation stations, airport safety equipment, and commodities used for security screening of passengers.
A U.S. negotiating team traveled to Havana this week to engage in talks about a new U.S.-Cuba air services agreement and we will keep you updated on any new developments.
Iran: The emerging diplomatic agreement with Iran will likely result in a near-term lifting of sanctions against Iran. Sanctions are likely to be lifted sometime in 2016 when the International Atomic Energy Agency certifies that Iran has complied with its obligations under the agreement (the so-called “Implementation Day”). Until then, non U.S.-persons involved in the export of U.S.-origin goods may apply for specific licenses authorizing export of such goods that are related to the inspection and repair and/or servicing of commercial aircraft in Iran. Secretary of State John Kerry has also announced that Ambassador Stephen Mull will be the U.S. Lead Coordinator on implementing the Iran deal.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com, 202-659-6622) or Drew Derco (dderco@eckertseamans.com, 202-659-6665).