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1119. Does General License (GL) O authorize all wind-down transactions for any vessel that was blocked on March 2, 2023?  What if the vessel contains Iranian-origin merchandise?


Iran GL Oauthorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 of Executive Order 13846 involving any vessel blocked as part of the March 2, 2023 designation (“blocked vessels”), subject to certain conditions.  This includes, among other activities, the unloading of any non-Iranian merchandise loaded on the blocked vessel as of March 2, 2023, provided there is no other sanctions nexus.  

U.S. persons are separately prohibited, pursuant to the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), from engaging in most Iran-related transactions.  Accordingly, for blocked vessels containing Iranian-origin merchandise or involving persons ordinarily resident in Iran, Iran GL O provides a separate, more limited authorization under the ITSR.  This narrower authorization under the ITSR allows only transactions ordinarily incident and necessary to certain limited safety and environmental situations:  the safe docking and anchoring of any of the blocked vessels in port; the preservation of the health and safety of the crew; or emergency repairs or environmental mitigation or protection activities.  The offloading of Iranian-origin petroleum, petroleum products, or petrochemical products, regardless of the situation, is not authorized pursuant to Iran GL O and requires a specific license from OFAC.

U.S. financial institutions may also process transactions conducted by non-U.S. persons if such transactions would be authorized for U.S. persons pursuant to Iran GL O.  

Iran GL O is in effect until 12:01 eastern daylight time, June 30, 2023.  Persons unable to complete authorized transactions involving the blocked vessels specified in Iran GL O before its expiration are encouraged to seek guidance from OFAC in advance of that date.  As with all OFAC GLs, Iran GL O only authorizes against the authorities identified in the GL and contains certain conditions.  Please see Iran GL O for further details.

Date Released
March 2, 2023