Sanctions: OFAC UPDATE 20120206

The President has signed a new Executive Order blocking the property and interests in property of the Government of Iran and Iranian financial institutions.

The E.O. requires U.S. persons to block all property and interests in property of the Government of Iran (including the Central Bank of Iran), of all Iranian financial institutions, and of all persons determined by the Secretary of the Treasury to be owned by, controlled by, or acting for or on behalf of any of those parties, when that property comes within the United States or within the possession or control of U.S. persons.

The E.O. builds upon the Iranian Transactions Regulations (“ITR”) and does not apply to certain Iranian property that was blocked in November 1979 and made subject to transfer directives in 1981.

Transactions involving the Government of Iran or Iranian financial institutions that previously needed to be rejected, now must be blocked, except that OFAC has issued two General Licences which, subject to certain exceptions, continue to allow transactions that were previously authorised by OFAC or not prohibited, including the transfer of personal remittances by U.S. depository institutions to and from Iran.

Please see the E.O., General License A and General License B, and “Frequently Asked Questions related to the Executive Order” for more information.
Users of OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List are encouraged to review this FAQ for guidance on how these changes affect the records on the SDN list.
Additional information on this action can be found in the Treasury Department's "Fact Sheet: Implementation of National Defense Authorisation Act Sanctions on Iran."

Links

Executive order (pdf): http://www.treasury.gov/resource-center/sanctions/Programs/Documents/iran_eo_02062012.pdf

Iranian Transactions Regulations: http://www.access.gpo.gov/nara/cfr/waisidx_10/31cfr560_10.html

General Licence A: http://www.treasury.gov/resource-center/sanctions/Programs/Documents/iran_gla.pdf

General Licence B: http://www.treasury.gov/resource-center/sanctions/Programs/Documents/iran_glb.pdf

Frequently Asked Questions re Executive Order: http://www.treasury.gov/resource-center/faqs/Sanctions/Pages/ques_index.aspx#iraneo