“The OFAC official was very satisfied when he found what compliance program we were using.”


OFAC’s Iran Sanctions Summary

The United States has imposed sanctions against Iran since 1979 in response to the country’s support for terrorist groups and its nuclear weapons program. While the restrictions have become increasingly stringent over the years, it is only recently that we have seen some of them being eased.

The U.S., E.U. China, Russia, and Iran signed The Joint Comprehensive Plan of Action (JCPOA) on July 14, 2015, to guarantee that Tehran’s nuclear program will be only for peaceful applications. On January 16, 2016, the International Atomic Energy Agency (IAEA) verified that Iran has complied with and implemented its key nuclear measures as described in the JCPOA.

However, many other sanctions on Iran are still in force because of the country’s support for terrorism, human rights abuses, proliferation of WMD’s and support for persons involved in human rights abuses in Syria and threatening the peace, security or stability of Yemen.

In general, unless licensed by OFAC, goods, technology or services may not be exported, reexported, sold or supplied, directly or indirectly, from the United States or by a U.S. person, wherever located, to Iran or the Government of Iran, including any brokering function from the United States or by U.S. persons, wherever located. A person may not export from the U.S. any goods, technology or services, if that person knows or has reason to know such items are intended specifically for supply, transshipment or reexportation to Iran. With certain exceptions, foreign persons who are not U.S. persons are prohibited from reexporting sensitive U.S.-origin goods, technology or services to Iran or the Government of Iran.

More specifically, the law covers the following areas:

Goods and Services

No goods, technology, or services may be exported, supplied, or sold, directly or indirectly by any U.S. person inside or outside the United States, to or from Iran or the Government of Iran. This includes financing export transactions with Iran, and brokering any dealings that benefit Iran or the Iranian government.

As for import, the United States is authorizing the importation of Iranian-origin carpets used as wall hangings classified under chapter 57 or heading 9706.00.0060 of the Harmonized Tariff Schedule; and foodstuffs including pistachios and caviar, intended for human consumption that are classified under chapters 2-23, all under a general license. These items will continue to be subject to all other laws and regulations applicable to imported good, including generally applicable laws and regulations controlled by other U.S. departments and agencies.

Oil and Gas

Under the current Iran sanctions, U.S. companies are not allowed involvement with petroleum development in Iran. This includes investment and trade in petroleum products from Iran and Iranian oil and gas companies, plus all petroleum and petrochemical companies identified by the U.S. Department of Treasury as being controlled by the Iranian government.

Financial Transactions

U.S. persons may not make any new investments (including loans or extensions of credit) in Iran or Iranian companies, including banks, or perform transactions or contracts with Iran. “U-Turn” transfers involving Iran, where the transfer originates and ends with non-Iranian foreign banks, are also prohibited. U.S. persons may not enter or facilitate entry to Iran. U.S. banks or their foreign branches may not service any financial accounts belonging to the Iranian government or persons in Iran.

Companies and individuals in breach of the sanctions are considered to be aiding a foreign entity hostile to the United States and its allies, and are liable to major penalties including criminal prosecution.

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