Iran – Don’t Forget the General License!

Iran entered into a historic nuclear agreement with the U.S. and other world powers on July 14th 2015. The agreement will allow the licensing of the export, re-export, sale, lease or transfer to Iran of commercial passenger aircraft for commercial and civil aviation use. The deal also grants the export of spare parts and components for commercial passenger aircraft.  It is reported that Iran is looking to replace hundreds of commercial aircraft.

Although this is potentially fabulous news for the commercial airline supply chain the lifting of such sanctions against Iran is not immediate.  The sanctions will be lifted and ultimately terminated in accordance with the deal’s “Implementation Plan,” As part of the plan, Iran will implement various nuclear-related measures and then the U.S. will then cease the application of various sanctions including those relating to “the sale of commercial passenger aircraft and related parts and services to Iran by licensing the export, re-export, sale, lease or transfer to Iran of commercial passenger aircraft for exclusively civil aviation end-use and the export of spare parts and components for commercial passenger aircraft.”  OFAC will be the agency in charge of drafting the new regulations.  No timeline is yet available concerning the export of civilian aircraft to Iran. With the UN Security Council vote behind us, there is now a 90 day time period before Implementation Day which will begin Iran’s implementation. During this period Congress will vote on the deal as well. Buckle your seat belts for the Congressional debate  and also start considering potential market opportunities for your company in the future.

Remember, it is a large market of more than 70 million people and the population is young. REMEMBER  Food, agricultural commodities, and medical suppliers already have a free pass to export.  Just remember to do your diligence and ensure compliance with the OFAC requirements.