Articles Posted in Iran Sanctions

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On August 7, 2018, the U.S. reinstated the first wave of sanctions against Iran as the 90-day wind-down period concluded. The Trump administration reimposed sanctions that prohibit Iran purchasing U.S. banknotes, commercial aircraft, trading gold and metals, and business with Iran’s automotive sector.

The snapback provisions were evoked by President Trump’s May 8, 2018 decision to withdraw from the 2015 Joint Comprehensive Plan of Action (“JCPOA”). Under direction from the Administration, federal agencies implemented 90-day and 180-day wind-down periods for activities involving Iran that were consistent with the sanctions relief detailed in the JCPOA.

In addition to the reinstatement of select pre-nuclear deal secondary sanctions, the Administration terminated JCPOA-related authorizations that permitted the importation of Iranian-origin carpets and foodstuffs; the exportation of civilian aircraft to Iran; and activities undertaken pursuant to General License I.

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The U.S. Treasury Department designated 16 entities and individuals for supporting “illicit Iranian actors or transnational criminal activity.” Read more here.

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Scope of TSRA license regarding the exportation of medical supplies to Iran broadened by the U.S. Department of the Treasury Office of Foreign Assets Control
On December 22, 2016, the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) amended the rules surrounding the General License for the exportation of medical devices to Iran.  See 31 C.F.R. Section 560.530.  Prior to the recent change, OFAC had published a list of medical supplies and devices that were eligible for exportation to Iran.  The exportation of all medical devices not included on the list would require a Specific License from OFAC.

OFAC’s recent action changed this inclusionary list to an exclusionary one.  Put differently, OFAC has now authorized the exportation of all medical devices to Iran except for products contained on a new shorter List of Medical Devices Requiring Specific Authorization (PDF).

The items on the List of Medical Devices Requiring Specific Authorization include advanced diagnostic imaging equipment, oxygen generators, high-volume pumps, and a long list of laboratory equipment.