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821. What does General License No. 8A (GL 8A) authorize with respect to humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC)?

Answer

As a result of the CBI and NIOC’s designations pursuant to  Executive Order 13224, as amended (E.O. 13224), U.S. persons are prohibited from engaging in any transaction or dealing in the property or interests in property of the CBI or NIOC under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), unless exempt or authorized by OFAC. In addition, U.S. persons and U.S.-owned or -controlled foreign entities are subject to broad prohibitions on transactions or dealings involving the CBI or NIOC under the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), unless exempt or authorized by OFAC.

GL 8A authorizes certain humanitarian-related transactions and activities involving the CBI, NIOC, or any entity in which NIOC owns a 50 percent or greater interest, that would be prohibited by the GTSR or by the ITSR as a result of the CBI and NIOC’s designations under E.O. 13224 but that would have been authorized under the ITSR prior to the relevant designation under E.O. 13224. For example, if a U.S. person could have relied on general or specific licenses pursuant to sections 560.530(a) or (b), 560.532, or 560.533 of the ITSR to engage in certain activities prior to the CBI or NIOC’s designations under E.O. 13224, GL 8A provides the additional authorization needed to engage in such activities.

Please note that GL 8A does not authorize humanitarian-related transactions involving Iranian financial institutions designated under E.O. 13224 other than the CBI. Please further note that the authorizations at sections 560.530, 560.532, and 560.533 remain otherwise applicable according to their terms.

Date Released
October 26, 2020