Before they run off to hit the eggnog, OFAC today published an amended Iranian Transaction and Sanctions Regulations (ITSR), as well as new and updated FAQs (on their FAQ page – not the separate JCPOA FAQ document). The changes expand the authorizations for medical devices and agricultural commodities that are licensable under the Trade Sanctions Reform and Export Enhancement Act (TSRA). Additionally, there are expansions of the authorizations for services and goods used for support of medical devices (including training, replacement parts and software, among other goods and services for operation, repair and maintenance), as well as for items that are broken or subject to product recalls. Lastly, OFAC has revised the definition of “Iranian-origin goods.” The revised ITSR will appear in the Federal Register tomorrow.
OFAC loves acronyms – you should have heard them flying around at the Fall Symposium.