… 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 … that knowingly engage in certain transactions with IRISL or E-Sail, even for the sale to… Read more
… these authorities is that the National Defense Authorization Act (NDAA) exception in the Iran Threat Reduction and Syria Human Rights Act (TRA) section 312 is limited to transactions or financial services for the purchase of petroleum or petroleum products from Iran…Read more
… Act” (Public Law 115-44) ( CAATSA ), which, among other things, imposes new sanctions on Iran. Section 105 of CAATSA requires the imposition of sanctions applicable pursuant to the global terrorism Executive Order 13224 on Iran’s Islamic Revolutionary Guard Corps… Read more
… set out in section 1 of E.O. 13590 — relating to development of petroleum resources in Iran and Iran’s domestic production of petrochemical products — were incorporated into subsections …
… could assist in or enable serious human rights abuses by or on behalf of the Government of Iran or the Government of Syria; or (2) to have sold, leased, or otherwise provided, directly or indirectly, goods, services, or technology to Iran or Syria likely to be… Read more
… proliferation), and E.O. 13553 (relating to serious human rights abuses by the Government of Iran) on October 16, 2018, and November 5, 2018. These included persons that had been removed … on November 5, 2018 as persons identified as meeting the definitions of the “Government of… Read more
… products to NIOC that fall below the dollar threshold that could trigger sanctions under the Iran Sanctions Act ). Executive Order 13622 also provides authority for the Secretary of the … Executive Order 13622. In addition, NIOC was already blocked as an entity of the Government… Read more