OFAC FAQ (Removed) # 806 - Iran-related FAQ (EO 13846)

Date issued: Dec. 19 2019

TURBOFAC Commentary (230 words)


*FAQ Removed at some point in 2020, presumably due to the expiry of Iran GL K.

1) This FAQ is a slight variation on FAQ 625 and FAQ 648, both of which deal with the scope of the term "maintenance" in the context of general licenses authorizing certain transactions with blocked parties.

There is one notable difference between this FAQ and the two others. OFAC says "OFAC will consider the transaction history between the party, or any intermediary party, and the General License K Covered Entities prior to September 25, 2019 in assessing whether activity is consistent with past practices."

The language concerning the "transaction history" between the sanctioned entity and "any intermediary party" is new to this FAQ, but given the parallelism between this FAQ and the other "maintenance" FAQs, it should be considered to apply across the board. For discussion of the likely rationale behind the addition of the "or any intermediary party" language, see comment to FAQ 807.

2) FAQ amended on 19 Dec, 2019 to account for the issuance of Iran General License (No. K-1), which extended the expiration date of the prior version.

3) See generally Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.

4) Web capture of original OFAC website not available - see text from three separate other sources.