§560.510 Transactions related to the resolution of disputes between the United States or United States nationals and the Government of Iran.
(a) Except as otherwise authorized, specific licenses may be issued on a case-by-case basis to authorize transactions in connection with awards, decisions or orders of the Iran-United States Claims Tribunal in The Hague, the International Court of Justice, or other international tribunals (collectively, "tribunals"); agreements settling claims brought before tribunals; and awards, orders, or decisions of an administrative, judicial, or arbitral proceeding in the United States or abroad, where the proceeding involves the enforcement of awards, decisions, or orders of tribunals, or is contemplated under an international agreement, or involves claims arising before 12:01 a.m. Eastern Daylight Time, May 7, 1995, that resolve disputes between the Government of Iran and the United States or United States nationals, including the following transactions:
(1) Importation into the United States...
1) This GL is substantially broader than its title, which is limited to disputes with "the Government of Iran," indicates.
While subsections (a) and (b) are statements of licensing policy, and subsection (d) is expressly limited to Hauge Claims Tribunal or other intergovernmental disputes, subsection (c) has been interpreted by OFAC as broadly authorizing a wide range of transactions related to ordinary commercial litigation involving Iran, Iranians and Iranian entities. In general, OFAC permits litigation against and involving Iranians and Iranian companies—and the use of "Iranian-origin goods and services" in connection with such legal proceedings—but the authorizations cut off at the payment of or receipt of payment in connection with a judgement or settlement arising from legal proceedings, unless authorized elsewhere.
Consult the following documents, and comments thereto, for further details:
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