OFAC FAQ (Current) # 1110 - Iran Sanctions

Date issued: Jan. 11 2023

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TURBOFAC Commentary (128 words)

Notes:

1) This FAQ, which was issued concurrently with the amendment of all other FAQs that had previously referenced Iran GL D-1, essentially conveys that which OFAC already conveyed in the Iran GL D-2-Related Press Statements/Briefings released along with GL D-2. See comments thereto. Of particular note, OFAC acknowledges that some/much of what GL D-2 explicitly authorizes was already implicitly authorized by GL D-1. (OFAC uses the terms "expanding" and "clarifying" to distinguish between substantive broadening of the GL and explicitly stating that which was previously only implicit). See Iran GL D-2, and comments thereto, for a detailed discussion on the changes between GL D-1 and GL D-2, and the scope of GL D-2 more generally.