ARTICLE
4 December 2019

OFAC Issues New And Updated FAQs On Iranian Sanctions

CW
Cadwalader, Wickersham & Taft LLP

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OFAC issued three new FAQs and updated two existing FAQs on U.S. sanctions against Iran.
Worldwide International Law
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OFAC issued three new FAQs and updated two existing FAQs on U.S. sanctions against Iran.

The new FAQs addressed changes made by Executive Order 13846 and General License K clarifying, respectively:

  • the ramifications of non-U.S. persons providing goods or services to non-Iranian persons sanctioned under section 3 of Executive Order 13846;
  • the types of activities that qualify as "maintenance" under General License K, authorizing the maintenance and wind-down of transactions involving COSCO Shipping Tanker (Dalian) Co., Ltd.; and
  • the conditions under which U.S. financial institutions can process transactions involving COSCO Shipping Tanker (Dalian) Co., Ltd.

OFAC also updated the FAQs regarding:

  • which insurance, reinsurance or underwriting activities are subject to sanctions under the Iran Freedom and Counter-Proliferation Act of 2012; and
  • the general non-applicability of sanctions to the corporate parent and affiliates of the COSCO Shipping Tanker (Dalian) Co., Ltd. and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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