Your OFAC Iran sanctions guidance is finally here, but you could have missed it in the weekend’s Iran-related events, which dominated the cable news networks and warranted a Cabinet Room address from President Obama.

Implementation Day came and went – as the International Atomic Energy Agency verified that Iran had met its nuclear-related commitments under the Joint Comprehensive Plan of Action (“JCPOA”) and the United States, Europe, and the United Nations did their part and lifted their nuclear-related sanctions on Iran in response.

The U.S. and Iran engaged in a prisoner exchange, in which seven Iranians either charged or convicted of U.S. sanctions violations (or other non-violent crimes) had their charges dropped or were granted clemency by President Obama in return for Iran’s release of four detained Iranian Americans and one American student in Tehran.

Finally, the U.S. and Iran entered into a settlement over certain outstanding claims at the U.S.-Iran Claims Tribunal – still ongoing after close to 35 years – in which the U.S. agreed to pay Iran the balance of $400 million in a Trust Fund that was used by Iran to purchase military equipment from the U.S. prior to 1979’s break in diplomatic relations. Iran’s claim for the funds had been pending since 1981, and the U.S. agreed to pay approximately $1.3 billion in interest to Iran as part of the settlement.

Events were fast-paced, which might have led some to lose sight of the fact that OFAC released its guidance related to the lifting of nuclear-related and certain other sanctions on Iran. As predicted, such release entailed a document providing broad guidance on the sanctions relief, a series of FAQs on specific questions related to the sanctions lifting, a new General License H, a new Statement of Licensing Policy regarding the export or re-export of commercial passenger aircraft and related parts and services to Iran, a regulatory amendment to the Iranian Transactions and Sanctions Regulations (“ITSR”) (31 C.F.R. §§ 560.534 and 560.535), an Executive Order 13599 List of entities determined to be Government of Iran or an Iranian financial institution and thus subject to blocking order in the United States, a notice providing for the de-listing of Iranian persons and entities listed in Attachment 3 to Annex II of the JCPOA from OFAC’s SDN List, and miscellaneous other items.

There is a lot to chew over in these newly-released materials, and we will have a series of posts this week relating to OFAC’s Iran sanctions guidance in order to elucidate new and interesting developments contained within, as well as to pull out key elements of the guidance itself. Nonetheless, it is important to point out that while these materials do point to a fundamental change in U.S. sanctions targeting the activities of foreign parties engaging in trade-related and other dealings with Iran or Iranian parties, little has changed with U.S. sanctions relating to the activities of U.S. persons vis-à-vis Iran. U.S. persons are thus especially advised to be on their guard in pursuing trade opportunities with Iran.  We will be sure to spell all this out and more in future posts.