OFAC FAQ (Current) # 805 - Iran-related FAQ (EO 13846)

Date issued: Nov. 27 2019

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TURBOFAC Commentary (836 words)

Notes:

1) Impliedly, this FAQ distinguishes the impact of being a non-Iranian person sanctioned under section 3 of EO 13846, as opposed to a non-Iranian person sanctioned under section 1 of EO 13846. A non-Iranian person sanctioned under section 1 of EO 13846 is a person with respect to whom the provision of material assistance can trigger designation. See Sec. 1(a)(iii)(B) of EO 13846.

2) The term "activity for which sanctions have been imposed with respect to Iran" is a rewording of "activity with respect to Iran for which sanctions have been imposed" (Sec. 1246(a)(1)(A) of IFCA). OFAC has not clearly defined what activities are activities "with respect to Iran for which sanctions have been imposed," but the context of Sec. 1246(a)(1)(A) of IFCA, read in conjunction with the secondary sanctions-specific example provided...