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1119. Does General License (GL) O authorize all wind-down transactions for any vessel that was blocked on March 2, 2023? What if the vessel contains Iranian-origin merchandise?
Iran GL O authorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 of Executive Order 13846 involving any vessel blocked as part of the March 2, 2023 designation (“blocked vessels”), subject to certain conditions. This includes, among other activities, the unloading of any non-Iranian merchandise loaded on the blocked vessel as of March 2, 2023, provided there is no other sanctions nexus.
U.S. persons are separately prohibited, pursuant to the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), from engaging in most Iran-related transactions. Accordingly, for blocked vessels containing Iranian-origin merchandise or involving persons ordinarily resident in Iran, Iran GL O provides a separate, more limited authorization under the ITSR. This narrower...
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1) Refer to Iran General License O for commentary and refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note).