823. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions or activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) that U.S. persons would be authorized to engage in under General License No. 8A (GL 8A)?

No. Non-U.S. persons generally do not risk exposure under U.S. secondary sanctions relating to Iran for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in otherwise applicable authorities, provided the transactions do not involve persons designated in connection with Iran’s support for international terrorism or weapons of mass destruction (WMD) proliferation. Non-U.S. persons do not risk exposure under U.S. secondary sanctions for engaging in humanitarian-related transactions or activities involving the CBI, NIOC, or any entity in which NIOC owns a 50 percent or greater interest, that would be authorized under GL 8A if engaged in by a U.S. person, provided such transactions and activities do not involve any person designated in connection with Iran’s support for international terrorism or WMD proliferation, other than the CBI, NIOC, or any entity in which NIOC owns a 50 percent or greater interest.