OFAC Issues New and Updated FAQs on Iranian Sanctions

OFAC issued three new FAQs and updated two existing FAQs on U.S. sanctions against Iran.

The new FAQs addressed changes made by Executive Order 13846 and General License K clarifying, respectively:

• the ramifications of non-U.S. persons providing goods or services to non-Iranian persons sanctioned under section 3 of Executive Order 13846;

• the types of activities that qualify as "maintenance" under General License K, authorizing the maintenance and wind-down of transactions involving COSCO Shipping Tanker (Dalian) Co., Ltd.; and

• the conditions under which U.S. financial institutions can process transactions involving COSCO Shipping Tanker (Dalian) Co., Ltd.

OFAC also updated the FAQs regarding:

• which insurance, reinsurance or underwriting activities are subject to sanctions under the Iran Freedom and Counter-Proliferation Act of 2012; and

• the general non-applicability of sanctions to the corporate parent and affiliates of the COSCO Shipping Tanker (Dalian) Co., Ltd. and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co.