Question and Answer 417 is being updated today to clarify that (i) payments to Iranian civil aviation authorities for overflights of Iran or emergency landing in Iran by aircraft that are owned by a non-U.S. person and registered outside the United States may not involve the U.S. financial system and (ii) U.S. persons and U.S.-owned or –controlled foreign entities cannot participate in transactions related to the payment of overflight or emergency landing fees to the Government of Iran, nor can such transactions transit the U.S. financial system, unless the transactions fall within the scope of 31 C.F.R. § 560.522 or a specific license issued by OFAC and the payments in connection with such authorized transactions are consistent with 31 C.F.R. § 560.516.
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