On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New  “General License J” authorizes many Boeing, Airbus, and other civil aircraft containing U.S.-origin materials to fly to Iran on “temporary sojourn.” The General License provides a great opportunity for non-U.S. aircraft owners and operators. However, a series of complex conditions may complicate ground handling agreements, damp or dry lease arrangements, code sharing, or other transactions related to providing service to Iran.
Continue Reading Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On January 16, 2016, two NFL playoff games and a historic revision of U.S. foreign policy took place. Many of us enjoyed the first two (did you see that last-second touchdown pass?!) but did not pay close attention as the United States lifted many of its secondary sanctions against Iran. Even those normally attentive to sanctions news had already heard (including by reading and excitedly discussing this blog) that things were not going to change that much for U.S. persons.
Continue Reading Airplanes, Pistachios, and a New Burger Joint in Tehran: What Changes for the United States Under Lighter Iran Sanctions

By: Reid Whitten

In Episode I: The Basics we noted that U.S. Export Control Reform may be causing confusion and consternation among those who will have to take the first theoretical rule changes and apply them in real and practical situations.  Among the first test subjects are those who oversee ITAR compliance for manufacturers and exporters of aircraft and aircraft parts.  While these brave souls will be the front line of the ECR implementers, those in the ranks behind (looking at you, Military Vehicles and Naval Vessels) will do well to learn from their experience.
Continue Reading Export Control Reform Series Episode II: The First Change – Reevaluating your ITAR Aircraft Parts