OFAC FAQ (Current) # 296 - Sanctions Relating to Iran’s Energy, Shipping, and Shipbuilding Sectors (IFCA)

Date issued: Sep. 05 2019

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TURBOFAC Commentary (690 words)

Notes:

1) This FAQ was amended on 9 Sep. 2019, in conjunction with the issuance of FAQ 691 and FAQ 692.

Prior to the amendment, the FAQ read as follows:

If a non-Iranian vessel is transporting non-sanctionable goods to or from Iran, bunkering in a third country will not be subject to sanctions provided that no other sanctionable activity is involved.

At the time the FAQ was initially issued, in 2013, it was an interpretation of the scope of the secondary sanctions contained in IFCA, CISADA and Sec. 1245 of the FY 2012 NDAA.

The amended version, by contrast, is a statement on the applicability of all secondary sanctions and derivative designation authorities active as of 9/2019. Compare FAQ 691, dealing with...