K. 13. Can U.S.-owned or -controlled foreign entities rely on GL H to export U.S.-origin goods to Iran?
No. GL H does not provide any authorization relating to the exportation or reexportation of U.S.-origin goods to Iran. Beginning on Implementation Day, unless the transactions are exempt from regulation or authorized by OFAC, U.S.-owned or -controlled foreign entities continue to be prohibited from the exportation, reexportation, sale, or supply, directly or indirectly, from the United States of any goods, technology, or services if the items are destined for Iran or the Government of Iran at the time they leave the United States. In addition, non-U.S. persons – including U.S.-owned or -controlled foreign entities – continue to be prohibited from reexporting from a third country, directly or indirectly, any goods, technology, or services that have been exported from the United States if they know or have reason to know...
1) Superseded/archived; Iran General License (No. H) revoked pursuant to JCPOA withdrawal.
2) Part of the FAQ generally restates Note 1 to paragraph (a) of GL H, the rest affirms that, notwithstanding the suspension of 560.215 for the JCPOA, 560.204 and 560.205 apply as they would have prior to the JCPOA.
3) The FAQ is notable for the purposes of post-JCPOA interpretations of 560.205 and 560.204, as the particular constructions used in the FAQ do not (as of 5/2019) appear in the regulations or other guidance.
"In addition, non-U.S. persons – including U.S.-owned or -controlled foreign entities – continue to be prohibited from reexporting from a third country, directly or indirectly, any goods, technology, or services that have been exported from the United States if...