ARTICLE
13 November 2020

OFAC Updates General License Authorizing Certain Transactions With Iran-Related Entities

CW
Cadwalader, Wickersham & Taft LLP

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OFAC updated a general license permitting transactions relating to humanitarian trade to cover certain dealings with the National Iranian Oil Company.
Worldwide International Law
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OFAC updated a general license permitting transactions relating to humanitarian trade to cover certain dealings with the National Iranian Oil Company ("NIOC"). The General License also includes any entity in which NIOC owns at a 50 percent or greater interest.

In General License 8A ("GL 8A"), OFAC authorized certain transactions involving NIOC that otherwise would be prohibited under the Global Terrorism Sanctions Regulations (or "GTSR") and the Iranian Transactions and Sanctions Regulations (or "ITSR"). Previously, the General License covered only transactions with the Central Bank of Iran ("CBI").

OFAC specified that the exportation or reexportation of goods to NIOC or CBI remains prohibited.

Additionally, OFAC amended six related FAQs to address the changes made by GL 8A and updated its Specially Designated Nationals and Blocked Persons List (or "SDN List") to include new Iran-related individuals, entities and vessels.

Primary Sources

  1. Treasury Press Release: Issuance of Iran-Related General License 8A and Amended Frequently Asked Questions; Counter Terrorism Designations and Designations Updates; Iran-Related Designations and Designations Updates
  2. OFAC General License 8A: Authorizing Certain Humanitarian Trade Transactions Involving the Central Bank of Iran or the National Iranian Oil Company
  3. OFAC FAQ: Iran Sanctions - 821
  4. OFAC FAQ: Iran Sanctions - 822
  5. OFAC FAQ: Iran Sanctions - 823
  6. OFAC FAQ: Iran Sanctions - 825
  7. OFAC FAQ: Iran Sanctions - 828
  8. OFAC FAQ: Iran Sanctions - 844

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