OFAC FAQ (Current) # 615 -FAQs Regarding EO of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran” - Sanctions on Petroleum-related Transactions

Date issued: Aug. 06 2018

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TURBOFAC Commentary (489 words)

Notes:

1) Concerning the following statement:

"These measures, which apply to transactions occurring on or after November 5, 2018, establish a key element of the comprehensive Iran sanctions framework by deterring work-around financial transactions involving NIOC or NICO that were not being captured under the sanctions previously implemented against the CBI at the time E.O. 13622 was issued."

Section 1(a)(iii) of EO 13846 provides for secondary sanctions, with no NDAA exemption, for persons that:

"on or after November 5, 2018, the person has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of" Iranian persons on the SDN list.

NICO and NIOC are on the SDN list. What OFAC...