Iran-China Energy Sanctions Act of 2023 (2024 "National Security Supplemental" - Public Law No: 118-50)

Date issued: Apr. 24 2024

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TURBOFAC Commentary (140 words)

Notes:

1) See the National Defense Authorization Act for Fiscal Year 2012, and comments thereto. This act amends Section 1245(d) of the National Defense Authorization Act for Fiscal Year 2012, which is implemented in the IFSR at section 561.203, to target transactions specifically by “Chinese financial institution” in a way that targets dealings with the Iranian petroleum / petroleum products sector as well as UAVs, and does so “without regard to the size, number, frequency, or nature of the transaction”. Note however that, notwithstanding the mandate to disregard “size, number, frequency, or nature of the transaction” from the considerations that go into the “significant financial transaction” determination (considerations which are codified at 561.404(a)-(b) of the IFSR), OFAC will still have broad discretion to determine a given transaction to be or not be “significant” for purposes...