On March 24, 2016 the Department of the Treasury Office of Foreign Assets Control issued General License I authorizing U.S. persons to negotiate and enter into contracts to export parts and services eligible for authorization under the Statement of Licensing Policy for Activities Related to the Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and Services.

Prior to General License I, a conundrum existed for U.S. persons seeking to apply for a license to export items under the SLP. Although the SLP provides for case-by-case review of license applications to export parts and services related to commercial passenger aircraft for civil aviation, U.S. persons were still prohibited from entering into contracts with Iran or even negotiating for contracts involving Iran. Exporters could not be sure if they were engaging in activities that required a license during the negotiation phase. To ensure compliance, potential exporters had to apply for an OFAC license to export items and services before they could even negotiate a sale.

Now, General License I allows U.S. persons to enter into and engage in transactions ordinarily incident to the negotiation of and entry into contingent contracts for export of items and services that are eligible for authorization under the SLP. Any such contract must be expressly contingent upon OFAC issuing a specific license authorizing the export. General License I does not authorize any transactions or negotiations with any individuals or entities on the Specially Designated Nationals List. Nor does General License I authorize any exports of goods or services.

General License I eliminates the dual-licensing problem, making the processing of applications under the SLP more efficient. For a license under the SLP, OFAC requires specific information regarding any proposed export including, for example, the types of aircraft to be exported, the Export Control Classification Numbers for all parts and technology, the Iranian recipient, and the proposed end-use. General License I now allows U.S. persons to negotiate those details prior to submission of a license application.

General License I can be found here.