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

Date issued: Jun. 03 2013

TURBOFAC Commentary (146 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 IFSR or any other regulations. This FAQ provides guidance on the scope of terms not otherwise defined in IFCA.

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 EO 13871. Graphite, for example, is subject to the IFCA sanctions, but not EO 13871, as implemented in the ISHRASR.

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