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692. Will the provision of bunkering services for an Iranian vessel be subject to sanctions?
Section 1244(d)(1) of IFCA makes sanctionable knowingly selling, supplying, or transferring to or from Iran significant goods or services used in connection with Iran’s energy, shipping, or shipbuilding sectors. (See FAQ 289 above for an interpretation of “significant.”) The provision of bunkering services to a vessel flying the flag of the Islamic Republic of Iran, or owned, controlled, chartered, or operated directly or indirectly by, for, or on behalf of the Government of Iran (GOI) or an Iranian person, could be sanctionable under this authority, regardless of whether the transaction involves persons that have been determined to be part of Iran’s energy, shipping, or shipbuilding sectors pursuant to Section 1244(c) of IFCA. Likewise, pursuant to section 1244(d)(2) of IFCA, a foreign financial institution could be exposed to sanctions if it knowingly conducts or...
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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.
2) This FAQ appears to be the first guidance specifying, or at least strongly suggesting, that all "[t]he provision of bunkering services to a vessel flying the flag of the Islamic Republic of Iran, or owned, controlled, chartered, or operated directly or indirectly by, for, or on behalf of the Government of Iran (GOI) or an Iranian person" can constitute, for the purposes of Sec. 1244(d) of IFCA, "supplying, or transferring to or from Iran...services used in connection with Iran’s...shipping...sector[]." If the vessels are in any way connected to Iran, they can be within the scope of the sanction at Sec. 1244(d) of