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807. Can U.S. financial institutions process transactions involving COSCO Shipping Tanker (Dalian) Co., Ltd. under Iran General License K-1 if the U.S. financial institution is the only U.S. person involved in the transaction?
Yes, provided the transaction is ordinarily incident and necessary to the maintenance or wind down of transactions involving, directly or indirectly, COSCO Shipping Tanker (Dalian) Co., Ltd., or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Co., Ltd., including any transaction or dealing in property or interests in property of the foregoing, subject to the conditions and expiration dates noted in Iran General License K-1 . However, please note that Iran General License K-1 does not authorize any transactions involving COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. or any entity owned, directly or indirectly, 50 percent or more by COSCO Shipping Tanker (Dalian) Seaman & Ship...
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*FAQ Removed at some point in 2020, presumably due to the expiry of Iran GL K.
1) *Note Common to FAQ # 807, FAQ # 835, FAQ # 841, FAQ # 883, FAQ # 1102 and FAQ # 1112
FAQ # 835, FAQ # 841, FAQ # 883, FAQ # 1102 and FAQ # 1112 all stand for the notable proposition as it relates to U.S. person facilitation of other involvement in underlying transactions of non-U.S. persons that are described by a general license, but not within the scope of OFAC's jurisdiction to begin with. More specifically, the FAQs all interpret standard wind down GLs that authorize "all transactions prohibited by the [sanctions] that are ordinarily incident and necessary to the wind down of any transaction involving [certain blocked...