New requirements for OFAC-issued general licenses A and B were issued earlier this year, effective with the Executive Order of February 6, 2012.

Individuals and businesses holding OFAC-issued licenses have been urged to confirm whether their transactions remain authorized, or whether a new license will be required.   The website instructions suggest General License A/specific licenses  — those arising from TSRA (Trade Sanctions Reform and Export Act of 2000) and the ITR (Iranian Transactions Regulations, 31 CFR part 560) – remain authorized through to license expiration.  Likewise, General License A/specific licenses that arise from 31 CFR Chapter V are generally authorized to license expiration, with an added twist.  If the license lacks an expiration date, then a default expiration date is set at April 6, 2012.

So, what rule should guide individuals and businesses who have a connection with Iran?  Prudence dictates that when in doubt, apply for a license.  The penalties and consequences are draconian, so it makes sense to err on the side of caution.  In the event no license is required, OFAC will provide a letter stating that no license is needed.  Remember, last quarter from July through to September, 2011, OFAC received 430 license applications relative to Iranian transactions.  Of these, 277 were issued, while only 1 was denied outright.  (OFAC Report of Licensing Activity Pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000, July – September 2011).