691 … If a non-Iranian vessel is transporting sanctionable goods to or from Iran (including, but not limited to, petroleum, petroleum products, or petrochemical products from Iran; goods used in connection with the automotive sector of Iran; or iron, iron products, aluminum, aluminum products,… Read more
692 … Section 1244(d)(1) of IFCA makes sanctionable knowingly selling, supplying, or transferring to or from Iran significant goods or services used in connection with Iran’s energy, shipping, or shipbuilding sectors. (See FAQ 289 above for an interpretation of “significant.”) The provision of… Read more
297 … The following transactions are excepted from the provisions of section 1244 of IFCA . a. Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran or for the provision of humanitarian assistance to the people of Iran. b. The export of petroleum or… Read more
346 … Due diligence programs should be tailored to the particular risks encountered by exporters. As a general matter, companies selling fee-based services, software, or hardware authorized by 31 CFR § 560.540 should undertake reasonable, risk-based measures designed to ensure that they do not… Read more
315 … Any company involved in loading or unloading cargo in Iran should exercise great caution to avoid engaging in transactions with entities designated by the United States, including the Tidewater Middle East Co. which was designated for its involvement in Iran’s proliferation of weapons of mass… Read more
298 … For purposes of IFCA , we anticipate that regulations to be promulgated will define graphite, raw or semi-finished metals described in section 1245(d) of IFCA to include steels; aluminum metal and its alloys; base metals of single or complex borides of titanium; beryllium metal and its alloys… Read more
961 … Yes. Support to municipal water systems by NGOs for projects that directly benefit the Afghan people or otherwise relieve human suffering that would otherwise be prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions… Read more
962 … Yes. Transactions that are ordinarily incident and necessary to give effect to the activities authorized in General Licenses (GL) 14 , GL 15 , GL 16 , GL 17 , GL 18 , GL 19 , or GL 20 , including clearing, settlement, and transfers through, to, or otherwise involving privately owned and… Read more
963 … Yes, cash shipments to Afghanistan may be authorized under General Licenses (GL) 14 , GL 18 , GL 19 , or GL 20 provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs. As with all OFAC GLs, GLs 14, 18, 19, and 20 are “self-executing,”… Read more
972 … Under the Russia-related CAPTA Directive , U.S. financial institutions are prohibited from the opening or maintaining of a correspondent account or payable-through account for or on behalf of, or from processing of a transaction involving, a foreign financial institution determined to be… Read more