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October 22, 2015: New FAQ regarding Iranian Diplomatic Missions

On the 22nd, OFAC issued a new FAQ regarding the JCPOA and delivery of routine goods and services by non-US persons to diplomatic missions of the Iranian government:

455. Is the provision of routine goods and services by non-U.S. persons to diplomatic missions of the Government of Iran located outside the United States sanctionable under U.S. law?

The provision of goods and services for the conduct of the official business of the diplomatic missions of the Government of Iran located outside the United States or for the personal use of the employees of the missions, including financial services such as the opening of a bank account, by a non-U.S. person would not be sanctionable under U.S. law, provided that such goods and services do not involve persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (other than any political subdivision, agency, or instrumentality of the Government of Iran listed solely pursuant to Executive Order 13599 or any Iranian depository institution listed solely pursuant to Executory Order 13599) or other activities that would be sanctionable under U.S. law.

Further, the provision of goods and services to the diplomatic missions of the Government of Iran outside the United States cannot involve U.S. persons or U.S.-owned or -controlled foreign entities, or the provision to the Government of Iran of goods, technology, or services subject to the prohibitions of 31 C.F.R. §§ 560.204-205, nor can related transactions transit the U.S. financial system, unless the activities and/or transactions are authorized by OFAC. [10-22-2015]

Hope that clears things up…. Domino's, you still can't deliver to an Iranian diplomatic mission, no matter how fast you get it there…

Links:

OFAC Notice

JCPOA FAQ of October 22, 2015

 

Categories: Frequently Asked Questions (FAQ) Guidance Iranian Sanctions Joint Comprehensive Plan of Action (JCPOA) Updates OFAC Updates Sanctions Programs Sanctions Regulations

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