We anticipate that regulations to be promulgated will define goods and services used in connection with Iran’s energy, shipping and shipbuilding sectors to include:
a. Energy Sector: In the case of Iran’s energy sector, goods or services that contribute to,
- Iran’s ability to develop its domestic petroleum resources;
- The maintenance or expansion of Iran’s domestic production of petroleum products; and
- Iran’s ability to import or export petroleum or petroleum products.
b. Shipping Sector: In the case of Iran’s shipping sector,
- The provision of crude and product tankers to Iran;
- The provision of registry, flagging, or classification services of any kind;
- The supervision of and participation in the repair of ships and their parts;
- The inspection, testing, and certification of marine equipment materials and components;
- The carrying out of surveys, inspections, audits and visits, and the issuance, renewal or endorsement of the relevant certificates and documents of compliance, as they relate to ships and shipping; and
- Any other goods or services relating to the maintenance, supply, bunkering, and docking of vessels flying the flag of the Islamic Republic of Iran, or owned, controlled, chartered, or operated directly or indirectly by, or for or on behalf of the Government of Iran (GOI) or an Iranian person.
c. Shipbuilding Sector: In the case of Iran’s shipbuilding sector,
- The building and refit of vessels;
- The provision or refit of items such as (i) steam turbines and their parts for marine propulsions, (ii) marine propulsion engines and parts used solely or principally with them, (iii) other gas turbines for marine propulsion, (iv) ship or boat propellers and blades, and (v) direction finding compasses and other navigational instruments and appliances solely for the maritime industry;
- Other goods used in connection with building and propulsion of vessels; and
- Technical assistance and training relating to, and financing of, the building, maintenance or re-fitting of vessels.
Sections 1244(d)(1) and (2) of IFCA make sanctionable certain transactions for the sale, supply, or transfer to or from Iran of such goods and services if they are significant goods or services used in connection with Iran’s energy, shipping, or shipbuilding sectors. (See FAQ 289 above for an interpretation of “significant.”) The provision of goods or services identified above could be sanctionable regardless of whether any person involved in the transaction has been determined to be part of Iran’s energy, shipping, or shipbuilding sectors.