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417. Are payments or the facilitation of payments not involving U.S. persons to Iranian civil aviation authorities for overflights of Iran or landing in Iran by aircraft that are owned by a non-U.S. person and registered outside the United States sanctionable under U.S. law?


No.  Provided that the relevant transactions do not involve the U.S. financial system or persons on the Specially Designated Nationals and Blocked Persons List (SDN List), payments of charges for services rendered by the Government of Iran in connection with the overflight of Iran or landing in Iran of aircraft owned by a non-U.S. person and registered outside the United States are not subject to sanctions under U.S. law.  The involvement of persons on the SDN List, including Iranian financial institutions or airlines designated pursuant to Executive Order 13224 or Executive Order 13382, would create sanctions exposure for participants to such transactions.

U.S. persons and U.S.-owned or -controlled foreign entities cannot participate in transactions related to the payment of overflight or landing fees to the Government of Iran, nor can such transactions transit the U.S. financial system, unless the transactions fall within the scope of 31 C.F.R. § 560.522 or a specific license issued by OFAC and the payments in connection with such authorized transactions are consistent with 31 C.F.R. § 560.516

Date Released
November 5, 2018