822. I’m a U.S. person that relied on general or specific licenses pursuant to 560.530, 560.532, or 560.533 of the ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. 13224, as amended. Is any further authorization needed to conduct such transactions following the designations of the CBI and NIOC under E.O. 13224?

No. As detailed in  FAQ 821, 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 due to the exclusion at section 560.530(d)(5) of the ITSR. Further authorization from OFAC, beyond GL 8A, is not required for such transactions and activities involving the CBI, NIOC, or any entity in which NIOC owns a 50 percent or greater interest, that would have been authorized pursuant to a general license in sections 560.530(a) or (b), 560.532, or 560.533 of the ITSR prior to CBI and NIOC’s designations under E.O. 13224, as amended. Additionally, transactions and activities authorized under specific licenses issued pursuant to sections 560.530, 560.532, or 560.533 of the ITSR involving the CBI, NIOC, or any entity in which NIOC owns a 50 percent or greater interest, are also authorized pursuant to GL 8A.

Any transactions otherwise prohibited by the ITSR or GTSR must be separately licensed pursuant to the ITSR or GTSR, as appropriate.