On the 22nd, OFAC issued a new FAQ regarding the JCPOA and delivery of routine goods and services by non-US persons to diplomatic missions of the Iranian government:

455. Is the provision of routine goods and services by non-U.S. persons to diplomatic missions of the Government of Iran located outside the United States sanctionable under U.S. law?

The provision of goods and services for the conduct of the official business of the diplomatic missions of the Government of Iran located outside the United States or for the personal use of the employees of the missions, including financial services such as the opening of a bank account, by a non-U.S. person would not be sanctionable under U.S. law, provided that such goods and services do not involve persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (other than any political subdivision, agency, or instrumentality of the Government of Iran listed solely pursuant to Executive Order 13599 or any Iranian depository institution listed solely pursuant to Executory Order 13599) or other activities that would be sanctionable under U.S. law.

Further, the provision of goods and services to the diplomatic missions of the Government of Iran outside the United States cannot involve U.S. persons or U.S.-owned or -controlled foreign entities, or the provision to the Government of Iran of goods, technology, or services subject to the prohibitions of 31 C.F.R. §§ 560.204-205, nor can related transactions transit the U.S. financial system, unless the activities and/or transactions are authorized by OFAC. [10-22-2015]

Hope that clears things up…. Domino's, you still can't deliver to an Iranian diplomatic mission, no matter how fast you get it there…

Links:

OFAC Notice

JCPOA FAQ of October 22, 2015

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In its entirety…

October 18, 2015

FREQUENTLY ASKED QUESTIONS RELATING TO ADOPTION DAY
UNDER THE JOINT COMPREHENSIVE PLAN OF ACTION

Q: What is Adoption Day?

A: Adoption Day, which is October 18, 2015, marks the date on which the Joint Comprehensive

Plan of Action (JCPOA) comes into effect.

Beginning on Adoption Day, JCPOA participants will start taking the steps necessary to
implement their JCPOA commitments. Importantly, Iran will now begin taking the nuclear-
related measures set forth in the JCPOA, and the United States and European Union will begin
the necessary additional work for the implementation of their commitments with respect to
sanctions under the JCPOA. Consistent with Annex V of the JCPOA, the United States issued
two documents on Adoption Day: the President issued a Memorandum to the Secretaries of
State, the Treasury, Commerce, and Energy to direct them to take all appropriate measures to
ensure the prompt and effective implementation of the U.S. commitments in the JCPOA; and the
Secretary of State issued contingent waivers of certain statutory sanctions in preparation for the
implementation of U.S. commitments with respect to sanctions under the JCPOA. Importantly,
these waivers will not take effect until confirmation by the Secretary of State that the
International Atomic Energy Agency (IAEA) has verified that Iran has implemented its key
nuclear-related measures described in the JCPOA (Implementation Day).

Q: Do the waivers that were issued on Adoption Day result in the lifting of any sanctions on
Adoption Day?

A: No. The waivers issued on Adoption Day are contingent on Iran verifiably taking key
nuclear-related steps outlined in the JCPOA, and the waivers do not take effect until the
Secretary of State has confirmed that Iran has verifiably taken those steps. Updated guidance
from the Department of the Treasury’s Office of Foreign Assets Control (OFAC) will reflect this
change once it occurs.

The only easing of sanctions in effect before Implementation Day continues to be that provided
for under the Joint Plan of Action of November 24, 2013, as extended. Until Implementation
Day, all other U.S. sanctions remain in effect, and certain activities involving Iran, such as
entering into contracts before Implementation Day with individuals and entities on OFAC’s List
of Specially Designated Nationals and Blocked Persons (SDN List), could expose the parties to
sanctions.

Q: When is Implementation Day and what will occur on that day?

A: The timing of Implementation Day and the associated sanctions lifting will depend on when
Iran fulfills its key nuclear-related commitments specified in the JCPOA. Once the IAEA
verifies that Iran has implemented these commitments under the JCPOA, the United States and the European Union will implement the first phase of their commitments with respect to the
JCPOA, as set out in Annex V of the JCPOA.

On Implementation Day, the lifting of U.S. nuclear-related sanctions described in sections 17.1-
17.2 of Annex V of the JCPOA will occur. To make this happen, the contingent waivers issued
on Adoption Day by the Secretary of State will take effect as noted above, and certain Executive
orders will be terminated as provided for in the JCPOA.

OFAC intends to publish on its website prior to Implementation Day detailed guidance and
information on the implementation of U.S. commitments with respect to sanctions under the
JCPOA. OFAC will also update its website on Implementation Day to notify the public that the
easing of U.S. sanctions pursuant to the JCPOA is in effect.

Even after Implementation Day, U.S. persons will continue to be broadly prohibited from
engaging in transactions or dealings involving Iran, including the Government of Iran, with the
exception of a few additional categories of transactions that the Treasury Department’s Office of
Foreign Assets Control (OFAC) will license pursuant to the JCPOA.

Q. Would the entry by non-U.S. persons into contracts involving Iranian entities prior to
the JCPOA Implementation Day be sanctionable?

A. Until Implementation Day, all U.S. sanctions against Iran remain in effect, with the exception
of the limited relief provided for in the Joint Plan of Action, as extended. Entering into contracts
involving Iran or its government before Implementation Day may be sanctionable. In certain
circumstances, this could include contracts that are contingent on the implementation of
sanctions relief under the JCPOA, such as contracts involving individuals or entities on the SDN
List. Until Implementation Day, we will continue to vigorously enforce the sanctions that remain
in effect.

As a general matter, unless authorized by OFAC, U.S. persons are prohibited from entering into
contracts – contingent or otherwise – involving Iran or its government, including with
individuals and entities on the SDN List.

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