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.
