Frequently Asked Questions

617 … Yes. As in E.O. 13622, E.O. 13846 defines NIOC and NICO to include any entity owned or controlled by, or operating for or on behalf of, NIOC and NICO. … E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or NICO subsidiary? Are… Read more

618 … No. Section 10 of E.O. 13846 maintains the exceptions previously provided for in E.O. 13622 and E.O. 13645, as well as in subsection 603(a) of the TRA and section 1254 of IFCA, for the pipeline project to supply natural gas from the Shah Deniz gas field in Azerbaijan to Europe and Turkey. …… Read more

619 … Yes. To the extent a financial institution is involved, that financial institution could be sanctioned under E.O. 13846 for a barter arrangement, on or after November 5, 2018, related to the purchase or acquisition of petroleum, petroleum products, or petrochemical products from Iran. In… Read more

266 … Yes. On September 24, 2012, NIOC was identified as an agent or affiliate of Iran’s Islamic Revolutionary Guard Corps (“IRGC”) under section 312 of the TRA , and designated on November 8, 2012, under E.O. 13382 for providing services and support to the IRGC. Accordingly, the Comprehensive Iran… Read more

609 … E.O. 13846 reimposes the sanctions previously contained in subsections 3(a)(ii) and section 5 of E.O. 13645 by authorizing the imposition of correspondent and payable-through account sanctions (subsection 2(a)(i)) of E.O. 13846) and menu-based sanctions (subsection 3(a)(i) of E.O. 13846) for… Read more

610 … E.O. 13846 defines the automotive sector of Iran as the manufacturing or assembling in Iran of light and heavy vehicles including passenger cars, trucks, buses, minibuses, pick-up trucks, and motorcycles, as well as original equipment manufacturing and after-market parts manufacturing… Read more

611 … E.O. 13846 reimposes sanctions on certain transactions on or after August 7, 2018, for the sale, supply, or transfer to Iran of “significant” goods or services used in connection with the automotive sector of Iran. (See FAQ 289 for an interpretation of the term “significant.”) We anticipate… Read more

267 … These definitions are set out in 31 CFR Part 561 . … What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “food, medicine, and medical devices,” “foreign financial institution,” and “country with primary jurisdiction over the …

612 … E.O. 13846 does not make sanctionable the export of finished vehicles to Iran if no further assembly or manufacturing is required. As such, exporting fully assembled and finished vehicles to Iran for sale would not be sanctionable, so long as the transaction is consistent with U.S. sanctions… Read more

613 … Goods or services for the maintenance of finished vehicles exported to Iran would generally not be considered “significant goods or services used in connection with the automotive sector of Iran” for the purposes of E.O. 13846 , and the provision of such goods or services would generally not… Read more