Iran Sanctions

617. E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or NICO subsidiary? Are transactions with those entities also sanctionable under this E.O.?

Yes. As in E.O. 13622, E.O. 13846 defines NIOC and NICO to include any entity owned or controlled by, or operating for or on behalf of, NIOC and NICO

August 6, 2018