Frequently Asked Questions

804 … COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co. was determined by the Secretary of State on September 25, 2019, to meet the criteria for the imposition of sanctions under Executive Order (E.O.) 13846 , and the Secretary of State imposed certain sanctions, including blocking,… Read more

805 … No, non-U.S. persons are generally not exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846 . However, please note that non-U.S. persons should ensure that the provision of goods or… Read more

810 … On November 5, 2018, OFAC identified IRISL and E-Sail on the SDN List with the [IRAN] tag to indicate that they are entities meeting the definition of the Government of Iran whose property and interests in property are blocked pursuant to E.O. 13599. Following their designation by the State… Read more

811 … The United States maintains broad authorizations and exceptions under U.S. sanctions that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran by U.S. and non-U.S. persons (see, e.g., FAQ 637 ). However, these authorizations and exceptions generally do… Read more

816 … Persons engaged in transactions that could be sanctioned under E.O. 13902 with respect to the construction, mining, manufacturing, and textiles sectors of the Iranian economy have a 90-day period after the issuance of E.O. 13902 to wind down those transactions without exposure to sanctions… Read more

821 … As a result of the CBI and NIOC’s designations pursuant to  Executive Order 13224 , as amended (E.O. 13224), U.S. persons are prohibited from engaging in any transaction or dealing in the property or interests in property of the CBI or NIOC under the Global Terrorism Sanctions Regulations, 31… Read more

822 … 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… Read more

823 … 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,… Read more

824 … On October 25, 2019, the U.S. Departments of State and the Treasury announced a new humanitarian framework to assist foreign governments and foreign financial institutions in establishing payment mechanisms to facilitate humanitarian exports to Iran that are subject to enhanced due diligence… Read more

825 … The SHTA is overseen by Switzerland’s State Secretariat for Economic Affairs (SECO) and intended for use by U.S. and non-U.S. persons domiciled in Switzerland. Exporters within Swiss jurisdiction may reach out to SECO at SHTA@seco.admin.ch for further details on requirements and instructions… Read more