OFAC FAQ (Current) # 298 - Sanctions Relating to the Sale, Supply, or Transfer of Certain Materials to or from Iran (relating to IFCA)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (145 words)

Notes:

1) Unlike the secondary sanctions provisions preceding IFCA, the statutory and executive order provisions that are the subject of these FAQs have not yet been implemented in the or any other regulations. This FAQ provides guidance on the scope of terms not otherwise defined in .

Note that the range of materials subject to the IFCA Sec. 1244 sanctions is far broader than those that are the subject of the secondary sanctions in 13871. Graphite, for example, is subject to the IFCA sanctions, but not EO 13871, as implemented in the .

2) See also Increasing Iran Metals Sanctions Targeting Iran’s Nuclear, Military, and Ballistic Missile Programs and the (IFCA Sec. 1245 Guidance).

3) See State Department Advisory on the Export of Metals Products to Iran. "Considered graphite, raw or semi-finished metals" appears to include graphite electrodes and needle coke.

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OFAC FAQ (Current) # 298 - Sanctions Relating to the Sale, Supply, or Transfer of Certain Materials to or from Iran (relating to IFCA)

TURBOFAC Commentary (145 words)