616. Can countries that receive a significant reduction exception under NDAA 2012 purchase oil through NIOC and NICO without facing sanctions?

All property and interests in property of NIOC and NICO subject to U.S. jurisdiction are already blocked pursuant to E.O. 13599, and U.S. persons are prohibited from all dealings with these entities. E.O. 13846 reestablishes the authority previously contained in E.O. 13622 to sanction FFIs that, on or after November 5, 2018, knowingly conduct or facilitate any significant transaction with NIOC or NICO. Financial institutions in jurisdictions that have received a significant reduction exception are not subject to these sanctions for transactions with NIOC and NICO for the purchase of petroleum or petroleum products from Iran while the exception applies. In addition, IFCA provides for sanctions on persons that knowingly provide significant financial, material, technological, or other support to, or goods or services in support of any activity or transaction on behalf of or for the benefit of an Iranian person on the SDN List (other than non-designated Iranian financial institutions), provided the person is not in a jurisdiction that has received a significant reduction exception. (See FAQs 293-297 relating to IFCA.)