GTSR/ITSR - General License 8A - Authorizing Certain Humanitarian Trade Transactions Involving the Central Bank of Iran or the National Iranian Oil Company

Date issued: Oct. 26 2020

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TURBOFAC Commentary (1048 words)


1) GTSR/ITSR - General License 8 was initially issued on 02-27-2020 to authorize certain transactions involving the Central Bank of Iran (CBI). It was amended on 10-26-2020 to add authorizations for certain transactions involving the National Iranian Oil Company (NIOC), or any entity in which NIOC owns, directly or indirectly, a 50 percent or greater interest.

2) Read in conjunction with 560.530, 560.532, and 560.533 of the ITSR. Those are the general licenses in the ITSR for TSRA-related (ag/med) goods.

When OFAC initially designated the CBI as a SDGT, U.S. persons were not permitted to engage in any transaction involving the CBI, even when those transactions were otherwise licensed...