OFAC FAQ (Current) # 620 -FAQs Regarding EO of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran” - Sanctions on Petroleum-related Transactions

Date issued: Aug. 06 2018

TURBOFAC Commentary (293 words)

Notes:

1) Definitions harmonious with 561.319 and 561.330 (defining those terms for IFSR purposes).

2) Compare with the guidance at FAQ # 323 JPOA Questions (removed).

Petrochemical products from Iran are defined in E.O. 13622 to include any aromatic, olefin, and synthesis gas, and any of their derivatives, including ethylene, propylene, butadiene, benzene, toluene, xylene, ammonia, methanol, and urea. Examples of such products include: butene, ethylhexanol, acetic acid, acrylonitrile butadiene styrene, alachlor, ammonium nitrate, ammonium sulfate, anhydrous ammonia, argon, butachlor, C2+, C3+, C4 cut, chlorinated paraffin, chlorine, chloracetyl chloride, citric acid, diammonium phosphate, diethanolamine, ethylene glycol, diethylene glycol, dioctyl phthalate, dodecycle benzene, ethane, ethoxylates, ethylbenzene, ethylene dichloride, ethylene glycol, ethylene oxide, heavy alkyl benzene, high density polyethylene, hydrochloric acid, isoprene, linear alkyl benzene, linear low density polyethylene, low density polyethylene, melamine, methyl tertiary butyl ether, methylene diphenyl diisocyanate, mid density polyethylene, monoethanolamine, monoethylene glycol, nitric acid, nitrogen, orthoxylene, paraxylene, pentene, perchlorine, phosphoric acid, phthalic anhydride, polybutadiene, polyethylene terephthalate, polypropylene, polystyrene, polyvinyl chloride, propylene, purified terephthalic acid, pyrolysis gasoline, raffinate, soda ash, sodium bicarbonate, sodium carbonate, sodium chloride, sodium hydroxide, sodium hypochlorite, styrene, tyrene acrylonite copolymer, sulfur, sulfuric acid, styrene butadiene, toluene diisocyanate, triethanolamine, triethylene glycol, and vinyl chloride monomer.

This list, however, is not exhaustive. The term "petrochemical products" does not include finished products derived from these substances, such as pipes, plastic bags, tires, and solvents; it also does not include bitumen, condensates, and other substances considered "petroleum products" under E.O. 13622.

3) Consult the State Department's illustrative lists of items falling within the scope of "Petroleum," "Petroleum products" and "Petrochemical products."

https://www.gpo.gov/fdsys/pkg/FR-2012-11-13/pdf/2012-27642.pdf, referred to in FAQ 323 (archived). See also Department of State: State Department Sanctions Information and Guidance (Public Notice 8086) (2012).