Yes. Pursuant to a general license at 31 CFR § 515.572(a)(3) , banking institutions, as defined in 31 CFR § 515.314 , U.S.-registered brokers or dealers in securities, and U.S.-registered money transmitters are permitted to process authorized remittances to or from Cuba without having to obtain a… Read more
In accordance with National Security Presidential Memorandum-5 on Strengthening the Policy of the United States Toward Cuba (NSPM-5) , the State Department publishes a list of entities and subentities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or… Read more
After 12:01 a.m. eastern daylight time, April 28, 2019, as described in Venezuela-related General License 7 and General License 12, any transactions (including swaps and non-cash transactions) involving the purchase or exchange of petroleum or petroleum products in which PdVSA or any entity in… Read more
Yes. Venezuela-related General License 10 authorizes U.S. persons in Venezuela to purchase refined petroleum products, including gasoline, for personal, commercial, or humanitarian uses from PdVSA, or any entity in which it owns, directly or indirectly, a 50 percent or greater interest. General… Read more
No. The GL for medical devices appearing at section 560.530 (a)(3)(i) of the Iranian Transactions and Sanctions Regulations ( ITSR ) authorizes covered persons, as defined in section 560.530(e)(4), to export or reexport to Iran medical devices as defined in section 560.530(e)(3) of the ITSR, except… Read more
No. While the GL under section 560.530 (a)(3)(i) of the Iranian Transactions and Sanctions Regulations ( ITSR ) authorizes exports or reexports of certain medical devices to most entities in Iran, it does not authorize exports or reexports to military, intelligence, or law enforcement purchasers or… Read more
The specified items excluded from the scope of the agricultural commodities general license are: castor beans, castor bean seeds, certified pathogen-free eggs (unfertilized or fertilized), dried egg albumin, live animals (excluding live cattle, shrimp, and shrimp eggs), embryos (excluding cattle… Read more
Yes. The definitions of the terms “agricultural commodities,” “medicine,” and “medical device” used in the relevant general licenses in the ITSR include, in the case of items subject to Commerce's Export Administration Regulations (EAR), items that are designated as EAR99 and, in the case of items… Read more
Yes. A non-U.S. person may export or reexport agricultural commodities, medicine, or medical devices to Iran under the relevant general licenses in the ITSR , provided that the items are subject to Commerce's Export Administration Regulations (EAR); and all conditions of the relevant general… Read more
If an export or reexport is not authorized by general license, any U.S. person, or non-U.S. person exporting items subject to Commerce's Export Administration Regulations (EAR); and designated as EAR99, wherever located, or U.S.-owned or -controlled foreign entity may apply for a specific license… Read more