General License 21A - Authorizing Limited Safety and Environmental Transactions Involving Certain Vessels (December 14, 2022)

Date issued: Jan. 12 2023

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TURBOFAC Commentary (175 words)

Notes:

1) On November 3, 2022, OFAC designated a number of holding companies and vessels for being "involved in blending oil to conceal the Iranian origins of the shipments and exporting it around the world in support of Hizballah and the IRGC-QF" (see https://home.treasury.gov/news/press-releases/jy1076).

Evidently, many of these vessels were at sea as of November 15, 2022, with otherwise innocent crew members aboard the vessels. This GL, which is unique among all active GLs, is aimed at mitigating the collateral damage from the blocking of the vessels.

2) Read in conjunction with FAQ # 1097, issued concurrently with this GL. The FAQ articulates OFAC's standard policy of not threatening designation of non-U.S. persons for activities that would be authorized for U.S. persons under...