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319. Does the GL for medical devices authorize the exportation or reexportation of these items to all entities in Iran?

Answer

No. While the GL under section 560.530(a)(3)(i) of the Iranian Transactions and Sanctions Regulations (ITSR) authorizes exports or reexports of certain medical devices to most entities in Iran, it does not authorize exports or reexports to military, intelligence, or law enforcement purchasers or importers, nor does it authorize exports or reexports to persons whose property and interests in property are blocked under any of the programs administered by OFAC, except for persons whose property and interests in property are blocked solely pursuant to Executive Order 13599 and the ITSR. When engaging in activities pursuant to this GL, exporters and reexporters are expected to undertake due diligence regarding all parties to the transactions, just as they would when acting pursuant to a specific license issued by OFAC.

Date Released
December 22, 2016