OFAC FAQ (Current) # 436 - Iran Sanctions (PDF contains all versions)

Date issued: May. 16 2024

Last substantive commentary amendment:
May. 17 2024

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TURBOFAC Commentary (344 words)

Notes:

* FAQ amended on 5-16-24 in connection with OFAC’s incorporation of Iran GL D-2 into the ITSR at section 560.540. Changes to the FAQ included certain non-substantive conforming amendments, along with language adding “provided” to “software not subject to the EAR that is exported, reexported, or provided, directly or indirectly, by a U.S. person located outside the United States.” This looks like a clarifying amendment rather than a substantive change. If a U.S. person located in France provides EAR99 software to a person in France that is ordinarily resident in Iran, this is an “exportation” to Iran for 560.204 purposes, but the term “provides” leaves no doubt that an intra-country transfer of that sort qualifies for the GL.

* On 9-23-22, OFAC replaced Iran GL D-1 with Iran GL D-2, initially without making amendments to this FAQ. See Iran GL...