OFAC Reimposed Iran Sanctions

On Aug. 6, OFAC revised existing Iran-FAQs for reimposed sanctions.

  • Follows White House Aug. 2018 executive order re-imposing sanctions re Iran.

OFAC Statement and FAQ

  • OFAC has revised statement and updated FAQ on implementation of May 2018
    decision to end US participation in joint comprehensive plan of action (JCPOA).
  • Implements Treasury May 2018 notice reimposing sanctions on Iran.
  • Decision reimposed all sanctions lifted or waived in connection with the JCPOA.
  • Aug. 8 marked the last day, of a 90-day wind-down of sanction relief specified.
  • Authorized Treasury to impose sanctions on person that does not meet criteria.
  • Amended existing FAQs re Iran freedom and counter-proliferation act of 2012.
  • Given revocation of prior EOs, archiving FAQs re EO 13622, 13628, and 13645.

US Currency and Metals

  • Sanction persons supporting Iran Government to acquire US banknote, metals.
  • If after Aug, 7, 2018, person materially assisted, sponsored, or given financial,
    material or technological support for, or goods or service supporting, purchase
    or acquisition of US banknotes, or precious metals, by the Government of Iran.

Oil, Shipping Sectors, Central Bank

  • Sanction supporters of Iran energy, shipping, shipbuilding sector, port operator.
  • If after Nov. 5, 2018, a person materially assists National Iranian Oil Company
    (NIOC), the Naftiran Intertrade, Company (NICO), or the Central Bank of Iran.

Supporters of Sanctioned Persons

  • Sanction those supporting certain Iranian person on list maintained by OFAC.
  • List of specially designated nationals and blocked persons maintained (SDN).
  • If after Nov. 5, 2018, a person materially assisted those named on OFAC list.

Blocks on Sanctioned Person

  • Block US property and interests of sanctioned person, in control of US person.
  • Blocked property may not be transferred, paid, exported, withdrawn or dealt.

Financing Petroleum and Auto

  • Sanction foreign financial institutions' US correspondent pay-through accounts.
  • If after Aug. 7, 2018, bank conducts, facilitates significant financial transaction
    related to sale, supply or transfer of goods or service to Iran automotive sector.
  • Or after Nov. 5, 2018, bank acts on behalf of Iranian person listed on SDN list
    or finances transaction, transportation, or marketing Iran petroleum products.

Permitted Petroleum Financing

  • Allows natural gas financing, if trade between country with primary jurisdiction
    over foreign financial institution and Iran, and funds paid to account in country.
  • Allow transaction for provision agricultural commodities, food, medicine to Iran.

Menu-Sanctions Re Petroleum

  • Menu-based sanctions may be applied to those assisting petroleum, auto sector.
  • By Treasury, Commerce, Homeland Security, USTR, EXIM bank, Federal Reserve.
  • Fed may stop sanctioned person as a 10 primary dealer in US Government debt.
  • May prohibit US bank giving loans or credits to sanctioned person above $10mn.
  • Ban forex trades under US jurisdiction, in which sanctioned person has interest.
  • Stop US transfers of credit or payments by, through, or to a financial institution.
  • Prohibit a US person from investing in the equity or debt of a sanctioned person.
  • Restrict or prohibit imports of goods, technology, or services to US from person.

Financing Iranian Rial

  • Sanction foreign financial institution involved in trading of Iranian rial currency.
  • For purchase, sale of derivative, swap, future, forward, contract related to Rial.
  • Where maintain funds or accounts outside Iran denominated in the Iranian Rial.
  • May prohibit foreign bank having US correspondent or payable-through account.
  • Block all property of foreign bank in US, from being transferred, paid, exported.

Technology for Rights Abuses

  • Sanction those transferring technology to Iran used in rights abuses, censorship.
  • If after Aug, 10, 2012, transferred, or facilitated goods or technology for abuse.
  • Where done knowingly, or likely to be used by Iran Government to abuse rights.
  • Including services re hardware, software, information, consulting, engineering.
  • Or provide financial, material, or technological support for those abusing rights.

Aug. 7, 2018 EU Blocking Statute