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642. Is the provision of certain associated services relating to the purchase of petroleum or petroleum products from Iran by persons in a country that has been granted a SRE sanctionable?


Many U.S. sanctions related to Iran include an exception for countries that have received a SRE under section 1245(d)(4)(D) of the NDAA 2012 (see https://ofac.treasury.gov/faqs/topic/1551 for additional information regarding the implementation of the SRE and sanctionable transactions). To the extent the purchase of petroleum or petroleum products from Iran and the processing of the related financial transactions meet the requirements set out in section 1245(d)(4)(D) of the NDAA 2012, the services used to import the petroleum from Iran including services provided by the shipping sector of Iran and Iranian port operators would not be sanctionable pursuant to the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA), provided that Iranian entities that are involved in such transactions are not designated in connection with Iran’s support for international terrorism, or its proliferation of weapons of mass destruction or their means of delivery. (Additional information on IFCA).

Date Released
November 5, 2018