These measures, which apply to transactions occurring on or after November 5, 2018, establish a key element of the comprehensive Iran sanctions framework by deterring work-around financial transactions involving NIOC or NICO that were not being captured under the sanctions previously implemented against the CBI at the time E.O. 13622 was issued. Iranian trade partners can continue to buy petroleum and petroleum products from Iran without risking sanctions under E.O. 13846 if they receive a significant reduction exception under relevant provisions of the NDAA 2012 for the relevant period. However, E.O. 13846 provides authority to sanction, on or after November 5, 2018, the purchase of petroleum or petroleum products and significant dealings with NIOC or NICO by persons in jurisdictions that do not have a significant reduction exception. In addition, IFCA provides for sanctions on persons determined to be part of the energy sector of Iran, or to sell, supply, or transfer to or from Iran significant goods or services used in connection with the energy sector of Iran, provided the person is not in a jurisdiction that has received a significant reduction exception. (See FAQs 293-297 relating to IFCA.)
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