No. For the purposes of evaluating sanctions pursuant to E.O. 13902, persons in Iran manufacturing medicines, medical devices, or products used for sanitation, hygiene, medical care, medical safety, and manufacturing safety, including soap, hand sanitizer, ventilators, respirators, personal hygiene products, diapers, infant and childcare items, personal protective equipment, and manufacturing safety systems, solely for use in Iran and not for export from Iran, will not be considered to be operating in the manufacturing sector of the Iranian economy. Note that persons conducting or facilitating transactions for the provision, including any sale, of agricultural commodities, food, medicine, or medical devices to Iran will not be subject to sanctions under E.O. 13902. (See FAQs 844 and 847 for more information.)
E.O. 13902 imposes sanctions with respect to any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate in the construction, mining, manufacturing, and textiles sectors of the Iranian economy, and any additional sectors of the Iranian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State. On October 8, 2020, the Secretary of the Treasury identified the financial sector of the Iranian economy for additional sanctions under E.O. 13902. Iranian and non-Iranian persons operating in these sectors could be subject to sanctions pursuant to E.O. 13902.
The United States maintains broad exceptions and authorizations that allow for the commercial sale and export of humanitarian goods, including medicine and medical devices, to Iran or the Government of Iran from the United States or by U.S. persons or U.S.-owned or -controlled foreign entities. Similar exceptions apply to the export of such humanitarian goods to Iran or the Government of Iran by non-U.S. persons. However, these authorizations and exceptions do not apply to transactions involving persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) that have been designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction (including certain designated Iranian financial institutions and the Islamic Revolutionary Guard Corps), or in connection with activity that is subject to other sanctions not specific to Iran, unless exempt or otherwise permitted, such as certain transactions or activities involving the Central Bank of Iran, the National Iranian Oil Company (NIOC), or any entity in which NIOC owns a 50 percent or greater interest, that are consistent with GL 8A. For further guidance related to humanitarian trade with Iran and the provision of humanitarian assistance to Iran, please see FAQ 828.