OFAC Compliance Guidance in re: Iran GL Q and in Rem Litigation

Date issued: Sep. 11 2025

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TURBOFAC Commentary (941 words)

Consolidated Comment on LICENSE No. IRAN-EO13902-2025-1414970-1 and OFAC Compliance Guidance in re: Iran GL Q and in Rem Litigation

[Update/Note - OFAC implemented EO 13902 into the ITSR subsequent to the drafting of the comment below. See 560.211 and comments thereto]

1) BACKGROUND

On April 22, 2025, OFAC designated the vessel TINOS I and certain associated persons, and on May 20, 2025, OFAC issued Iran General License Q, which authorized (among other things) “[t]he sale of the Tinos I, provided the net proceeds of the sale be placed into a blocked interest-bearing account at a U.S. financial institution.” The GL contained an interpretive note specifying that “[t]ransactions authorized by paragraph (a)(5) include: bidding on...