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New Iran listings, changes to Iran & counter-terror listings, new Iran GL & FAQ

Today, OFAC added the following people:

ARANI, Hossein Firouzi (Arabic: حسین فیروزی آرانی), Iran; DOB 22 Dec 1964; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); National ID No. 6199571101 (Iran); Managing Director of Bakhtar Commercial Company; CEO of Bakhtar Commercial Company (individual) [IRAN-EO13846] (Linked To: BAKHTAR COMMERCIAL COMPANY). 
 
BAHREINI, Amir Hossein (Arabic: امیر حسین بحرینی), Tehran, Iran; DOB 21 Sep 1973; POB Tehran, Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); National ID No. 0068653263 (Iran); Managing Director of Arya Sasol Polymer; CEO of Arya Sasol Polymer (individual) [IRAN-EO13846] (Linked To: ARYA SASOL POLYMER). 
 
BASRAI, Murtuza Mustafamunir (a.k.a. BASRAI, Murtuza Munir), 125 Meyer Road, 27-04, The Makena, 437936, Singapore; DOB 29 Jul 1971; POB Surat, India; nationality India; Gender Male; Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); National ID No. S7160185D (Singapore); Director of Strait Shipbrokers PTE. LTD.; Managing Director of Strait Shipbrokers PTE. LTD. (individual) [IRAN-EO13846] (Linked To: STRAIT SHIPBROKERS PTE. LTD.). 
 
OLADI, Ramezan (Arabic: رمضان اولادی), Iran; DOB 29 May 1963; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); National ID No. 2162049082 (Iran); Managing Director of Kavian Petrochemical Company; CEO of Kavian Petrochemical Company; Vice Chairman of the Board of Kavian Petrochemical Company (individual) [IRAN-EO13846] (Linked To: KAVIAN PETROCHEMICAL COMPANY). 
 
WEI, Lin Na (a.k.a. WEI, Linna (Chinese Simplified: 魏琳娜)), No. 5, The Lotus Pond, Hecheng District, Huaihua, Hunan Province, China; DOB 28 Nov 1980; POB Yunyan District, Guiyang, Guizhou Province, China; nationality China; Gender Female; Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); National ID No. 520103198011285623 (China); Director of Binrin Limited (individual) [IRAN-EO13846] (Linked To: BINRIN LIMITED). 

and entities:

ARYA SASOL POLYMER (Arabic: پلیمر اریا ساسول) (a.k.a. ARYA SASOL POLYMER CO.; a.k.a. ARYA SASOL POLYMER COMPANY; a.k.a. ARYA SASOL POLYMERS; a.k.a. ARYASASOL POLYMER COMPANY; a.k.a. ARYASASOL POLYMERS; a.k.a. POLIMER ARYA SAASOOL; a.k.a. POLYMER ARIA SASOL COMPANY; a.k.a. “ASPC”), Qian Tower, No 2551, Vali-e-Asr Avenue, Naseri Street, P.O. Box: 15875-8393, Tehran 1968643111, Iran; Pars Energy Specific Economic Zone, Lenj Square, Kangan, Assaluyeh, Bushehr Province 7511811365, Iran; No. 114, 10th Street, Qaem Maqame Farahani Street, Tehran, Iran; 7th Floor, Kian Tower, No. 2551, Naseri St., Vali-e-Asr Ave, Tehran, Iran; Nakhl Taghi City, Nakhl Taghi Road, Kolmeter 15, Number 0, Ground Floor Kangan, Bushehr 7511811365, Iran; Phase 1 Petrochemical, Special Petrochemical Zone Assaluyeh, Tehran, Iran; Website http://www.aryasasol.com; Additional Sanctions Information – Subject to Secondary Sanctions; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); National ID No. 10320053498 (Iran); Registration Number 777 (Iran) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
BAKHTAR COMMERCIAL COMPANY (Arabic: شرکت بازرگان کالای باختر) (a.k.a. “BCCO”), North Kargar Street, Above Taghateh Fatemi, Plaque 1286, Tehran 73441-14118, Iran; No. 1286, North Karegar Avenue, Tehran, Iran; Ashrafi Esfahani Highway, Fourth Road Punak, Falahzadeh Boulevard, Plaque 40, Floor 5, Tehran, Iran; Website http://www.bcco.co; Additional Sanctions Information – Subject to Secondary Sanctions; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); National ID No. 10320817213 (Iran); Registration Number 429515 (Iran) [IRAN-EO13846]. 
 
BINRIN LIMITED (Chinese Traditional: 丙林有限公司), Room A3, 9/F., Goodwill Industrial Building, No 36-44 Pak Tin Par Street, Tsuen Wan, New Territories, Hong Kong, China; Flat H29, 1/F, Phase 2 Kwai Shing Ind. Bldg., No. 42-46 Tai Lin Pai Road, Kwai Chung, New Territories, Hong Kong, China; Unit 1307, Beverly commercial Centre, 87-105 Chatham South Road, Tsim Sha Tsui, Kowloon, Hong Kong, China; Additional Sanctions Information – Subject to Secondary Sanctions; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); C.R. No. 2725675 (Hong Kong) [IRAN-EO13846] (Linked To: ARYA SASOL POLYMER). 
 
ELFO ENERGY HOLDING LIMITED, Hong Kong, China; Additional Sanctions Information – Subject to Secondary Sanctions; C.R. No. 2917743 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
GLORY ADVANCED LIMITED, Hong Kong, China; Additional Sanctions Information – Subject to Secondary Sanctions; C.R. No. 2811523 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
JANE SHANG CO., LIMITED, Hong Kong, China; Additional Sanctions Information – Subject to Secondary Sanctions; C.R. No. 2674480 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
JIAXIANG ENERGY HOLDING PTE. LTD., 24 Raffles Place, #11-01 Clifford Centre, 048621, Singapore; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 201708444M (Singapore) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
KAVIAN PETROCHEMICAL COMPANY (a.k.a. KAVIAN PETROCHEMICAL (Arabic: پتروشیمی کاویان); a.k.a. KAVIAN PETROCHEMICAL CO.; a.k.a. KAVIAN PETROCHEMICAL COMMERCIAL; a.k.a. KAVIAN PETROCHEMICAL CORPORATION; a.k.a. KAVIAN PETROCHEMICAL PRIVATE JOINT STOCK COMPANY (Arabic: شرکت پتروشیمی کاویان سهامی خاص)), Fatemi Street West Corner Khazan Alley, Plaque 2, Tehran, Iran; Petro Kavian, Asalouye, Bushehr 7539175146, Iran; Pars Special Energy Economic Zone, Kavian Petrochemical Complex, Asalouyeh, Iran; North Kargar Street, Plaque 310, Fourth Floor, Tehran, Iran; West Fatemi Street, Corner of Khazan Alley, Number 2, Tehran, Iran; Ashrafi Esfahani Highway, Fourth Road Punak, Falahzadeh Boulevard, Plaque 40, Floor 5, Tehran, Iran; 4th Floor No. 310, North Kargar Ave., Shahid Fatemi Cross Upsards, Tehran, Iran; Kavian Petrochemical Co., PSEEZ, Asaluyeh, Iran; Website http://www.petrokavian.com; Additional Sanctions Information – Subject to Secondary Sanctions; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); National ID No. 10102953996 (Iran); Registration Number 255100 (Iran) [IRAN-EO13846]. 
 
MORVARID PETROCHEMICAL (a.k.a. MORVARID PETROCHEMICAL CO), No. 29, North Shahanaghi Alley, Sheikh Bahaie Shomali Street, Mollasadra Street, Tehran, Iran; PO Box 15855-516, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Registration Number 1524 (Iran) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
SIBSHUR LIMITED, Hong Kong, China; Additional Sanctions Information – Subject to Secondary Sanctions; C.R. No. 2826353 (Hong Kong) [IRAN-EO13846] (Linked To: TRILIANCE PETROCHEMICAL CO. LTD.). 
 
STRAIT SHIPBROKERS PTE. LTD. (a.k.a. STRAIT SHIPBROKERS SINGAPORE PTE. LTD.), 1 North Bridge Road, #22-06 High Street Centre, 179094, Singapore; Website http://www.straitship.com; Executive Order 13846 information: LOANS FROM UNITED STATES FINANCIAL INSTITUTIONS.  Sec. 5(a)(i); alt. Executive Order 13846 information: FOREIGN EXCHANGE.  Sec. 5(a)(ii); alt. Executive Order 13846 information: BANKING TRANSACTIONS.  Sec. 5(a)(iii); alt. Executive Order 13846 information: BLOCKING PROPERTY AND INTERESTS IN PROPERTY.  Sec. 5(a)(iv); alt. Executive Order 13846 information: BAN ON INVESTMENT IN EQUITY OR DEBT OF SANCTIONED PERSON.  Sec. 5(a)(v); alt. Executive Order 13846 information: IMPORT SANCTIONS.  Sec. 5(a)(vi); alt. Executive Order 13846 information: SANCTIONS ON PRINCIPAL EXECUTIVE OFFICERS. Sec. 5(a)(vii); Registration Number 200512056R (Singapore) [IRAN-EO13846]. 

to its Iran sanctions program under its Executive Order 13846 authority.

And the following 2 listings under both Iran and counter-terror programs were updated:

AL-BILAD ISLAMIC BANK FOR INVESTMENT AND FINANCE P.S.C. (a.k.a. AL BILAD ISLAMIC BANK), 37 Building El-Karadeh 909 Street 1 Near Al Hurea Square, Baghdad, Iraq; Al Masbah Branch, Baghdad Al Masbah Intersection, 929 Street 17 Bldg. 40, Previously the German Embassy, Baghdad, Iraq; Erbil Branch, Erbil Province, 60 Bldg 354/132, 45 Street, Erbil, Iraq; Al Mawarid Branch, Baghdad – Street 62 Neighboring the Department of Electricity, Baghdad, Iraq; Al Nasiryah Branch, Zi Kar Province El Saray, Bldg. 2/239 Janat Al Janoub Hotel Building, Nasiryah, Iraq; Al Basra Branch Al Basra, Manawy Pasha Corniche Street, Basra, Iraq; Al Sadr Branch, Jameela District – 8-22-512, Sadr City, Iraq; Al Jaderya Branch Baghdad, Al Jaderya – Versus Baghdad University, 906 Street 28 – Dar 3, Baghdad, Iraq; Karbala Branch Karbala, Al Dareeba Intersection, Karbala, Iraq; Al Najaf Branch, Al Najaf Al Ashraf, Al Amir District – Al Koufa Street, Najaf, Iraq; Zakho Branch Dahook, Zakho – Ibrahim Al Khaleel Street, Baydar Boulevard, Zakho, Iraq; Al Mansour Branch Baghdad, Al Mansour-12-G 605-M-Bldg, Baghdad, Iraq; Babel Branch Babel, Kalaj – Al Honood Branch, Babel, Iraq; Beirut Branch Lebanon, Beirut – Hamra Street, Broadway Center – Versus Costa Caf, Lebanon, Beirut, Lebanon; SWIFT/BIC AIIFIQBA; Website http://www.Bilad-Bank.com; Additional Sanctions Information – Subject to Secondary Sanctions; All Branches Worldwide [SDGT] [IRGC] [IFSR] (Linked To: KAREEM, Aras Habib). -to- AL-BILAD ISLAMIC BANK FOR INVESTMENT AND FINANCE P.S.C. (a.k.a. AL ATAA ISLAMIC BANK FOR INVESTMENT AND FINANCE; a.k.a. AL ATTA ISLAMIC BANK FOR INVESTMENT AND FINANCE; a.k.a. AL BILAD ISLAMIC BANK; a.k.a. AL-ATAA ISLAMIC BANK; a.k.a. AL-ATTA ISLAMIC BANK; a.k.a. AL-ATTAA ISLAMIC BANK), 37 Building El-Karadeh 909 Street 1 Near Al Hurea Square, Baghdad, Iraq; Al Masbah Branch, Baghdad Al Masbah Intersection, 929 Street 17 Bldg. 40, Previously the German Embassy, Baghdad, Iraq; Erbil Branch, Erbil Province, 60 Bldg 354/132, 45 Street, Erbil, Iraq; Al Mawarid Branch, Baghdad – Street 62 Neighboring the Department of Electricity, Baghdad, Iraq; Al Nasiryah Branch, Zi Kar Province El Saray, Bldg. 2/239 Janat Al Janoub Hotel Building, Nasiryah, Iraq; Al Basra Branch Al Basra, Manawy Pasha Corniche Street, Basra, Iraq; Al Sadr Branch, Jameela District – 8-22-512, Sadr City, Iraq; Al Jaderya Branch Baghdad, Al Jaderya – Versus Baghdad University, 906 Street 28 – Dar 3, Baghdad, Iraq; Karbala Branch Karbala, Al Dareeba Intersection, Karbala, Iraq; Al Najaf Branch, Al Najaf Al Ashraf, Al Amir District – Al Koufa Street, Najaf, Iraq; Zakho Branch Dahook, Zakho – Ibrahim Al Khaleel Street, Baydar Boulevard, Zakho, Iraq; Al Mansour Branch Baghdad, Al Mansour-12-G 605-M-Bldg, Baghdad, Iraq; Babel Branch Babel, Kalaj – Al Honood Branch, Babel, Iraq; Beirut Branch Lebanon, Beirut – Hamra Street, Broadway Center – Versus Costa Caf, Lebanon, Beirut, Lebanon; SWIFT/BIC AIIFIQBA; Website http://www.Bilad-Bank.com; Additional Sanctions Information – Subject to Secondary Sanctions; All Branches Worldwide [SDGT] [IRGC] [IFSR] (Linked To: KAREEM, Aras Habib). 
 
MADANIPOUR, Mahmoud, 93 Chiltern Road, Sutton, SM2 5QZ, Surry, United Kingdom; Iran; DOB 19 Jul 1978; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Passport Y42996343 (Iran) issued 10 Oct 2022 (individual) [SDGT] [IFSR] (Linked To: MOBIN INTERNATIONAL LIMITED). -to- MADANIPOUR, Mahmoud, 93 Chiltern Road, Sutton, SM2 5QZ, Surry, United Kingdom; Iran; DOB 19 Jul 1978; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male; Passport Y42996343 (Iran) expires 10 Oct 2022 (individual) [SDGT] [IFSR] (Linked To: MOBIN INTERNATIONAL LIMITED). 

By the way, if you can tell me what changed – especially with Madanipour – let me know. It’s not painfully obvious – I’ve compared the before and after multiple times.

Also note that most, but not all of the new EO 13846 designations list which sanctions were imposed. If nothing is listed, are they all in force?

Additionally, a new General License M is very of-the-moment – you can now provide online educational services and send software to certain students that can’t come to the US because of the pandemic.

Lastly, there is a related Frequently Asked Question (FAQ):

853. Can U.S. academic institutions provide online learning services to Iranian students who are not physically present in the United States because of the Coronavirus Disease 2019 (COVID-19) pandemic?  Can U.S. technology companies provide software and services to assist Iranian students in accessing online coursework?

Answer

General licenses issued under the Iranian Transactions and Sanctions Regulations (ITSR) authorize certain U.S. academic institutions and other U.S. persons to provide certain services and software to Iranian students.  These general licenses include:

  • General License G (GL G) authorizes accredited graduate and undergraduate degree-granting U.S. academic institutions, including their contractors, to export services to students located in Iran, or located outside of Iran but who are ordinarily resident in Iran (“Iranian students”), to sign up for and participate in certain undergraduate level online courses, notably:  (i) courses in the humanities, social sciences, law, or business that are the equivalent of courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business; and (ii) introductory undergraduate level science, technology, engineering, or mathematics courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business.  In addition, under Section 560.405 of the ITSR, certain transactions ordinarily incident to a licensed transaction are also authorized.  OFAC interprets Section 560.405 of the ITSR to authorize certain transactions ordinarily incident to courses authorized by GL G, including the giving of assignments and testing and grading of Iranian students.  
  • General License M (GL M) authorizes, on a time-limited basis, accredited graduate and undergraduate degree-granting U.S. academic institutions, including their contractors, to export additional services to those Iranian students who are eligible for non-immigrant classification under categories F (students) or M (non-academic students), and have been granted a nonimmigrant visa by the U.S. State Department, but are not physically present in the United States due to the COVID-19 pandemic.  Specifically, GL M authorizes the provision of certain online educational services related to:  educational courses that are (i) the equivalent of courses ordinarily required for the completion of graduate degree programs in the humanities, social sciences, law, or business; and (ii) introductory science, technology, engineering, or mathematics courses ordinarily required for the completion of graduate degree programs in the humanities, social sciences, law, or business.  OFAC interprets Section 560.405 of the ITSR to authorize certain transactions ordinarily incident to courses authorized by GL M, including the giving of assignments and testing and grading of Iranian students.  GL M also authorizes the exportation of certain software to facilitate the participation of certain Iranian students in certain online educational activities, as explained further below.  GL M authorizes covered activities through 12:01 a.m. eastern daylight time September 1, 2021.
  • Section 560.540 of the ITSR and General License D-1 authorize the exportation to Iran of certain services and software incident to the exchange of personal communications over the Internet, such as instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, and blogging.  OFAC interprets these authorizations to cover video conferencing software and related services, as well as educational technology software and related services, that allow students to view courses and course materials, complete tests and assignments, receive grades, participate in discussions, and other, similar course-related online activity, provided that the software meets the additional criteria of the applicable authorization.  For more guidance on Section 560.540 of the ITSR and General License D-1, please see FAQs 337, 338, 339, 340, 341, 342, 343, 344, 345, 346, 347, 348, 434, 435, 436, 437, 438, 439, 440, 441, 442, and 443.  In addition, GL M also authorizes the exportation of certain software in order to facilitate participation in online educational activities described in GL G and GL M by Iranian students who are eligible for non-immigrant classification under categories F (students) or M (non-academic students), and have been granted a nonimmigrant visa by the U.S. State Department, but are not physically present in the United States due to the Covid-19 pandemic.

To export services to Iranian students that fall outside of these authorizations, U.S. persons may apply for a specific license through the OFAC License Application Page.  OFAC is committed to mitigating the adverse impacts of the COVID-19 pandemic and prioritizes the review of specific license applications to provide online learning services to Iranian students who are not physically present in the United States because of the COVID-19 pandemic.  

Please note that the general licenses summarized above do not authorize the exportation of goods (including software), services, or technology to the Government of Iran or to persons blocked under any authority administered by OFAC, including OFAC’s counterterrorism or counterproliferation authorities. 

Links:

OFAC Notice

General License M

New FAQ

Categories: Executive Orders Frequently Asked Questions (FAQ) Guidance Iranian Sanctions Licenses OFAC Updates Sanctions Lists

eric9to5

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