Further weakening secondary sanctions, the Department of Treasury’s Office of Foreign Assets Control has issued a new license to allow non-U.S. persons to fly some U.S. aircraft to Iran for temporary sojourn. While General License J only applies to fixed-wing airplanes and imposes a number of conditions that must be met in order for non U.S.-persons to fly to Iran, the new license may mark the start of new opportunities for the civil aviation industry in Iran.
Airplanes re-exported under the license must not stay in Iran for more than 72 hours and must not be registered in the United States. Further, the non-U.S. person exporter must maintain the right to hire and fire the cockpit crew, dispatch the airplane, determine its routes, and perform all principal maintenance on the airplane. These controls and others are meant to ensure that no technology is transferred to Iranian nationals ordinarily resident in Iran.
The license also allows non-U.S. persons to send certain spare parts, components, and technology to Iran for permanent use so long as it is ordinarily incident and necessary for the operation of the airplane.
Although the license opens up a narrow opportunity, it is an important step toward further commercial transactions.