OFAC FAQ (Current) # 1135 - Iran Sanctions

Date issued: Sep. 18 2023

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TURBOFAC Commentary (227 words)

Notes Common to FAQ 1134 and FAQ 1135

Compare FAQ # 824, FAQ # 825 and FAQ # 826, describing the "Swiss Humanitarian Trade Arrangement," and see Financial Channels to Facilitate Humanitarian Trade with Iran and Related Due Diligence and Reporting Expectations, which goes into detail about "Enhanced Due Diligence and Reporting Expectations" in a way that, one might assume, would reflect the "stringent due diligence measures" under the "humanitarian channel in Qatar".

Note that the timing of the announcement of the HQ coincides with Iran's release of certain U.S. prisoners held in Iran, in exchange for the U.S. waiving the application of secondary sanctions on the release of $6bn in Iranian funds. See https://www.reuters.com/world/us-allows-6-billion-transfer-part-iran-prisoner-swap-2023-09-11 (reporting on the secondary sanctions waiver notification to congress starting that "[t]o facilitate [the prisoners'] release, the United...