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Lise S. Test

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The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued an FAQ providing guidance relating to the provision of humanitarian goods and assistance to Iran in response to the Coronavirus Disease 2019 outbreak there. The guidance summarizes existing legal authorities that may authorize such humanitarian activities, which include: The making of humanitarian donations from the US or by US persons to recipients in Iran (other than to the Government of Iran, persons on…

On February 20, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published two new Frequently Asked Questions regarding the interim final rule of June 21, 2019 that amended the Reporting, Procedures and Penalties Regulations, 31 CFR Part 501 (the “RPPR Rule”). These FAQs hope to clarify some of the issues that arose from the interim final rule but still leaves areas of uncertainty, such as what constitutes a rejected transactions. For example,…

The United States has imposed additional sanctions on Iran in the wake of Iran’s missile strike on military bases in Iraq. On January 10, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had added 8 senior Iranian government officials and 17 Iranian metals producers and mining companies to the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, President Trump issued a new Executive Order, “Executive Order on Imposing Sanctions with Respect to Additional Sectors of Iran” (the “Order”), authorizing the imposition of secondary sanctions on certain transactions involving the construction, mining, manufacturing, and textiles sectors of the Iranian economy.

On December 11, 2019, the US State Department announced the designations of the Islamic Republic of Iran Shipping Lines (“IRISL”), its China-based subsidiary, E-Sail Shipping Company Ltd (“E-Sail”), and Mahan Air, a privately-owned airline based in Tehran, under Executive Order 13382 (“E.O. 13382”), for their involvement in the transporting of weapons of mass destruction (“WMD”).  All three entities had previously been designated to the Specially Designated Nationals and Blocked Persons List (“SDN List”) administered by US Treasury Department’s Office of Foreign Assets Control (“OFAC”). OFAC will implement the new designations by adding the [NPWMD] and [IFSR] tags to the SDN List entries of IRISL and E-Sail effective June 8, 2020. OFAC updated the Mahan Air entry effective immediately. OFAC published two related Frequently Asked Questions, FAQs 810 and 811.