1120. Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized to engage in under Iran General License (GL) O?

No.  Non-U.S. persons generally do not risk exposure to sanctions for engaging in activities or facilitating transactions for such activities that would be authorized for U.S. persons pursuant to GL O .  Non-U.S. persons unable to wind down transactions in accordance with Iran GL O before 12:01 a.m. eastern daylight time, June 30, 2023, are encouraged to seek guidance from OFAC in advance of that date.