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OFFICE OF FOREIGN ASSETS CONTROL
Executive Order 13846 of August 6, 2018
Reimposing Certain Sanctions With Respect to Iran
GENERAL LICENSE K-1
Authorizing Maintenance or Wind Down of Transactions Involving COSCO Shipping Tanker (Dalian) Co., Ltd.
(a) Except as provided in paragraph (b) of this general license, all transactions and activities prohibited pursuant to section 5 of Executive Order (E.O.) 13846 that are ordinarily incident and necessary to the maintenance or wind down of transactions involving, directly or indirectly, COSCO Shipping Tanker (Dalian) Co., Ltd., or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Co., Ltd., including any transaction or dealing in property or interests in property of the foregoing, are authorized through 12:01 a.m. eastern standard time February 4, 2020.
(b) This general license does not authorize:
(1) Any transactions or activities with COSCO Shipping Tanker (Dalian) Seaman and Ship Management Co., Ltd., or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Seaman and Ship Management Co., Ltd.;
(2) The unblocking of any property blocked pursuant to E.O. 13846, or any part of 31 C.F.R. chapter V, except as authorized by paragraph (a); or
(3) Any transactions or activities prohibited by E.O. 13846, except as authorized by paragraph (a) of this general license, or any transaction or activity prohibited by any other E.O. or any part of 31 C.F.R. chapter V, including any transaction or activity involving Iran, the Government of Iran, or Iranian-origin goods or services that is prohibited by the Iranian Transactions and Sanctions Regulations (31 C.F.R. part 560).
(c) Effective December 19, 2019, General License K, dated October 24, 2019, is replaced and superseded in its entirety by this General License K.
Dated: December 19, 2019
1) Broad GL authorizing transactions "ordinarily incident and necessary to the maintenance or wind down of transactions involving" Cosco Shipping Tanker (Dalian) Co., Ltd. See generally documents related to the scope of "wind down" and "maintenance" general licenses.
The GL appears to have the effect of unblocking all or virtually all funds and physical property of that entity, at least insofar as the only reason for their blocking was an interest in the property had by Cosco. Compare also Venezuela General License 11, where text similar to what is found in paragraph (a) here is acknowledged, in paragraph (c), as covering the unblocking of property.
Note the entity is Chinese, and was secondarily sanctioned for oil-related transactions involving Iran. Hence the caveat that the GL excludes any transaction that would implicate primary Iran-related sanctions, such as the ITSR.
2) The scope of the GL is further discussed in FAQ 804, FAQ 806, FAQ 807. FAQ 807 is particularly valuable as it specifies that U.S. person banks, and presumably all non-U.S. persons, may facilitate transactions not involving U.S. persons where the underlying transaction facilitated would be within the scope of the GL if they did involve U.S. persons.
3) GL Amended on Dec. 19, 2019 to extend the expiration date.
4) On Jan. 31, 2020, the entities within the scope of Iran GL K were removed from the SDN list. See https://web.archive.org/web/20200516140740/https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20200131.aspx.
*For expired/superseded versions of this GL, see https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/venezuela-related-sanctions/archive-of-revoked-and-expired-general-licenses. We note that while we have included some expired and/or revoked GLs in the research system as stand-alone searchable items, we avoid clutter by removing GLs once they have been superseded by amended versions.