(We previously wrote about some of the reported difficulties in exporting medical supplies to Iran.) While E.O. These questions gained a sense of urgency in March, after Iran became one of the epicenters of the COVID-19 outbreak. 13902 raised a number of questions about which types of companies and transactions OFAC included in those sectors and which goods and services counted as “significant” or were “used in connection” with those sectors. The expansion of secondary sanctions under E.O. financial institutions that facilitate “significant” financial transactions involving those sectors. 13902 also authorizes the Treasury Secretary via OFAC to sanction non-U.S. individuals and entities if they operate in or knowingly engage in a “significant” transaction for the sale or supply to or from Iran of “significant” goods or services “used in connection with” the Iranian construction, mining, manufacturing, or textiles sectors. 13902 mean that OFAC may sanction non-U.S. secondary sanctions against Iran to include transactions involving the construction, mining, manufacturing, and textiles sectors of the Iranian economy and authorized the Secretary of the Treasury to add more sectors as he sees fit. On January 10, 2020, President Trump issued Executive Order (“ E.O.”) 13902, which expanded U.S. In the Iran sanctions program, there are currently secondary sanctions applicable to transactions involving many Iranian persons listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (“ SDN List”), the Iranian energy, shipping, and automotive sectors, and even the Central Bank of Iran (“ CBI”), among others. sanctions against Iran include both types of sanctions but stand out in the scope and number of secondary (or “extraterritorial”) sanctions threatened against non-U.S. persons for transactions outside the United States and which threaten sanctions against foreign persons for sanctionable conduct, including engaging in certain business involving Iran). nexus and carry potential monetary penalties for violations) and “secondary” sanctions (which apply to non-U.S. sanctions are often categorized into “primary” sanctions (which apply to U.S. sanctions against Iran do not prevent Iranian companies and individuals from obtaining medical supplies and safety equipment necessary to fight the COVID-19 epidemic or endanger Iranian workers. The new FAQs continue OFAC’s recent efforts to ensure that U.S. These FAQs define the construction, mining, manufacturing, and textile sectors of the Iranian economy and clarify that OFAC will not view sales of humanitarian, safety, and sanitation-related goods/services to persons in Iran who are not Specially Designated Nationals (“ SDNs”) as operating in these sectors or transacting in goods or services used in connection with these sectors. Treasury Department’s Office of Foreign Assets Control (“ OFAC”) issued four new frequently asked questions (“ FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions program earlier this year. government permissions.On June 5, 2020, the U.S. content or any item intended to support weapons-proliferation activities, unless they have all applicable U.S.
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See to check the applicable Part of Title 31, Code of Federal Regulations (CFR), Chapter V for exempt transactions and general licenses to see if there is an exception for your item(s).įor more information on how to apply for an OFAC license, please see “Applying for a BIS Export License” on page 10 “Applying for an OFAC License.”Ĭustomers are prohibited from shipping any item with controlled U.S.
#Ofac general license iran medical license
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