OFAC FAQ (Current) # 804 - Iran-related FAQ (EO 13846)

Date issued: Dec. 19 2019

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TURBOFAC Commentary (314 words)

Notes:

1) See Secondary Sanctions Enforcement Announcement - China Concord Petroleum Co., Limited, Kunlun Shipping Company Limited, Pegasus 88 Limited, and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co, Ltd. (2019). The State Department announced the imposition of blocking sanctions, pursuant to Sec 3(a)(ii) and 3(a)(v) of EO 13846, on entities that were involved with the export of crude oil from Iran and certain entities owning/controlling those entities that had knowledge of the transactions.

This FAQ does not provide "interpretative guidance" as it relates to the sort of transactions that are theoretically within the scope of designation authorities but which OFAC will decline to impose sanctions. Instead, the only purpose of the FAQ appears to be to clarify the scope of the sanctions that were imposed. OFAC clarifies the ultimate parent of one of the entities blocked,...