Iran General License O - Authorizing Wind-Down and Limited Safety and Environmental Transactions Involving Certain Vessels

Date issued: Mar. 02 2023

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TURBOFAC Commentary (1126 words)

Notes:

1) Read in conjunction with FAQ # 1119 and FAQ # 1120, issued concurrently.

2) This GL authorizes otherwise prohibited transactions involving entities and vessels concurrently designated for the transport of petrochemical and petroleum products from Iran. See Designating Iran Sanctions Evaders (State Dep't Press Statement). From the context of the GL, it is presumed that the vessels in the annex, or at least some of them, were at sea with Iranian-origin product at the time of the designations.

3) WIND DOWN AS APPLIED TO BLOCKED VESSELS

In FAQ # 1119, OFAC explains that "Iran GL O authorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 of Executive Order 13846 involving any vessel blocked as part of the March 2, 2023 designation ('blocked vessels'),...