Guidance
The question (No 306): How does the Executive Order relate to the IFCA provisions? The answer: The E.O. provides additional tools related to the IFCA provisions by: a. Authorizing prohibitions or restrictions on the importation of goods; and b. Implementing the statutory requirements of section 105C of the Comprehensive Iran […]
The question (No 305): Sanctions under section 1247 of IFCA apply to FFIs that facilitate financial transactions on behalf of an Iranian person on the SDN List. How does the Executive Order relate to section 1247? The answer: The E.O. tightens the financial sanctions applicable to FFIs under section 1247 […]
The question (No 303): Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under section 1246(a)(1)? The answer: A number of insurance activities are subject to sanctions under IFCA, including providing insurance, reinsurance, or underwriting services to persons on the SDN List sanctioned for activities with respect to […]
The question (No 302): Are there any exceptions to section 1245 of IFCA? The answer: A person will not be subject to sanctions under section 1245 of IFCA if a determination is made by the Department of the Treasury or the Department of State, as appropriate, that the person has […]
The Iranian sanctions program has a General License for the provision of “basic medical supplies” to Iran. Today, OFAC updated that list of supplies under a new General License. They also added two questions to its Frequently Asked Questions (FAQ) page, and issued updated “Guidance on the Sale of Food, […]
That's the focus of my article in the July-August issue of FX-MM – combing through OFAC settlements so your firm knows the landmines to avoid. It's just been put up on the Publications page – you can also get to it here. If you're more of an AML person, I […]
The question (No 301): How will the determination be made as to whether materials are used in a manner that would make them subject to sanctions under section 1245 of IFCA? The answer: A FFI, prior to conducting or facilitating a significant financial transaction for the sale, supply, or transfer […]
The question (No 300): For purposes of sanctions under section 1245, how will I know which sectors are controlled by Iran’s Islamic Revolutionary Guard Corps? The answer: By July 1, 2013, a report will be published in the Federal Register with respect to which sectors of the Iranian economy are […]
The question (No 299): What are considered precious metals? The answer: For purposes of IFCA, we anticipate that regulations to be promulgated will define the term “precious metals” to include silver (including silver plated with gold or platinum, unwrought or in semi-manufactured forms, or in powder form); gold (including gold […]
The question (No 298): What materials are considered graphite, raw or semi-finished metals? The answer: For purposes of IFCA, we anticipate that regulations to be promulgated will define graphite, raw or semi-finished metals described in section 1245(d) of IFCA to include steels; aluminum metal and its alloys; base metals of […]
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