OFAC FAQ (Current) # 691 - Sanctions Relating to Iran’s Energy, Shipping, and Shipbuilding Sectors (IFCA)

Date issued: Sep. 05 2019

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TURBOFAC Commentary (403 words)

Notes:

1) FAQ 691 and FAQ 692 were both issued on the same day, concurrent with the amendment of FAQ 296, dealing with provision of bunkering services to a non-Iranian vessel carrying non-sanctionable goods to or from Iran. (Emphasis added).

This FAQ essentially serves to indicate that bunkering services provided even to non-Iranian vessels can be considered the provision of "material assistance" to NIOC or NICO in connection with purchase of oil from those entities. See Sec. 1(a)(ii) of EO 13846. OFAC appears to signal that it would use derivative designation or secondary sanctions authorities in connection with bunkering services provided to non-Iranian vessels carrying any type of "sanctionable goods," but read in conjunction with FAQ 296, where OFAC also appears to signal that it will not sanction bunkering services provided to non-Iranian vessels carrying goods in...