OFAC updates FAQs related to Iranian humanitarian goods manufacturing

Financial Crimes OFAC Department of Treasury Sanctions Iran Of Interest to Non-US Persons

On June 5, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued updated Iran-related FAQs related to Executive Order (E.O.) 13902 concerning the treatment of Iranian manufacturers that provide humanitarian goods. As previously covered by InfoBytes, E.O, 13902 authorizes the Secretary of the Treasury, in conjunction with the Secretary of State, to impose asset blocking sanctions on any person determined to operate in the construction, mining, manufacturing or textile sectors of the Iranian economy, or any additional sector as they may jointly determine. Additionally, EO 13902 authorizes the imposition of certain sanctions on any person determined to have engaged in, or any foreign financial institution determined to have knowingly facilitated, a significant transaction involving one of the aforementioned sectors of the Iranian economy. The FAQs state that OFAC will not target persons in Iran manufacturing humanitarian goods, such as “medicines, medical devices, or products used for sanitation or hygiene” as long as the products are “solely for use in Iran and not for export from Iran.” The FAQs also define Iranian economy sectors, specify what constitutes as “significant goods or services,” and clarify the interpretation of “‘knowingly’ and ‘significantly reduced’” for purposes of E.O. 13902. Additionally, on June 8, OFAC added several Iran-related designations to its Specially Designated Nationals List.