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OFAC publishes final rule for IFSR amendments

The final rule implements sections 503 and 504 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (aka “TRA”), which affects the Iranian Financial Sanctions Regulations (“IFSR”) and the National Defense Authorization Act of 2012 (“NDAA”). Bottom line on the significant changes:

  • Foreign banks can be sanctioned if they do significant business with the Central Bank of Iran or other designated Iranian banks. The change adds agricultural commodities to the list of goods that are not considered for imposition of sanctions.
  • The changes make it clear that, while foreign central banks will not be sanctioned under the NDAA, other government-controlled or owned banks can be.
  • Countries who significantly reduce their imports of Iranian oil can get limited-time exemptions. The changes not only put some restrictions on these exemptions, they also more clearly define what “significant” means

The Federal Register can be a tough read – lots of history there and lots of detailed references to bits and pieces of US law and regulation.

Luckily, OFAC also published a FAQ about Section 504, which deals with the exemptions for significant reduction of crude oil imports.


OFAC Press Release
Final Rule published in Federal Register
Section 504 FAQ

Categories: Iranian Sanctions OFAC Updates


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