No. Non-U.S. persons generally do not risk exposure to U.S. secondary sanctions for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in E.O. 13902 and other applicable sanctions authorities.
However, such transactions should not involve persons designated on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction (WMD) unless 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.
Additionally, non-U.S. persons do not risk exposure to U.S. secondary sanctions for engaging in transactions and activities involving the Iranian financial sector or an Iranian FI blocked pursuant to E.O. 13902 that would be authorized under the Iranian Transactions and Sanctions Regulations (ITSR) and GL L if engaged in by a U.S. person, provided such transactions and activities do not involve any person designated on the SDN List in connection with Iran’s support for international terrorism or proliferation of WMD.