OFAC FAQ (Current) # 624 -FAQs Regarding EO of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran” - Sanctions Relating to the Provision of Material Assistance to Certain Persons

Date issued: Aug. 06 2018

Last substantive commentary amendment:
Jun. 12 2023

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TURBOFAC Commentary (469 words)

Notes:

OCT-17-2020 UPDATE: "Iranian depository institutions whose property and interests in property are blocked solely pursuant to Executive Order 13599" should be amended to account for the blocking of such entities pursuant to both EO 13599 and EO 13902 (see Comment on the Designation of the Iranian Financial Sector Pursuant to EO 13902).

1) Sec. 1(a)(iii) of EO 13846 is a "material assistance" derivative designation criterion applicable to all Iranian SDNs, other than "13599-only banks."* This sanction has no explicit agricultural/medical exemption, and has no exemption for purchases of oil from NIOC/NICO by persons from countries with valid SRE waivers. Notwithstanding the extraordinary theoretical breadth of the sanction, OFAC has confirmed that it will not apply sanctions for transactions otherwise exempt from secondary sanctions. See FAQ # 615...