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.