On November 5, OFAC re-designated over 700 individuals, entities, aircraft, and vessels linked to Iran, against whom secondary sanctions had previously been lifted pursuant to the JCPOA. Re-imposition of US nuclear sanctions against Iran also included renewed prohibitions on a variety of Iran-related activities, including non- US persons' involvement in business activities related to:
- Iran's port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping Lines (IRISL), South Shipping Line Iran, or their affiliates;
- Petroleum-related transactions with, among others, the National Iranian Oil Company (NIOC), Naftiran Intertrade Company (NICO), and the National Iranian Tanker Company (NITC), including the purchase of petroleum, petroleum products, or petrochemical products from Iran;
- Transactions by foreign financial institutions with the Central Bank of Iran and designated Iranian financial institutions under Section 1245 of the National Defense Authorization Act for Fiscal Year 2012 (NDAA);
- The provision of specialized financial messaging services to the Central Bank of Iran and Iranian financial institutions described in Section 104(c)(2)(E)(ii) of the Comprehensive Iran Sanctions and Divestment Act of 2010 (CISADA);
- The provision of underwriting services, insurance, or reinsurance; and
- Iran's energy sector.
In addition to new designations, a full listing of the over 700 re-designated persons can be found on the following Department of Treasury website: https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20181105_names.aspx.
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.
