OFAC Releases Additional Frequently Asked Questions Relating to the Implementation of the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) and Executive Order 13645

Questions Related to the Issuance of the Executive Order “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Freedom and Counter-Proliferation Act of 2012 and Additional Sanctions With Respect to Iran” and the Implementation of Certain Provisions of the Iran Freedom And Counter-Proliferation Act of 2012 (IFCA)
On June 3, 2013, the President signed an Executive Order (E.O.) “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Freedom and Counter-Proliferation Act of 2012 and Additional Sanctions With Respect to Iran.” The E.O. implements certain statutory provisions of the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) and authorizes the imposition of additional sanctions with respect to Iran. Most of the IFCA provisions target conduct occurring on or after July 1, 2013. The E.O. becomes effective on July 1, 2013.
General Questions
313 What is the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA)?
288 What is the purpose of the Executive Order of June 3, 2013 entitled “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Freedom and Counter-Proliferation Act of 2012 and Additional Sanctions With Respect to Iran” (E.O.)?
Iran Freedom and Counter-Proliferation Act of 2012
289 How will the following IFCA terms be interpreted: “Iran,” “knowingly,” “significant,” “transfer,” “Iranian person included on the SDN List ”?
290 Are payments or deliveries that are made on or after July 1, 2013, for contracts that existed prior to July 1, 2013, exempted from IFCA provisions?
291 How does the Executive Order relate to the IFCA provisions?
292 What are the implications of IFCA on the provision of humanitarian goods to the people of Iran?
Sanctions Relating to Iran’s Energy, Shipping, and Shipbuilding Sectors
IFCA provides for sanctions involving activities or transactions related to Iran’s energy, shipping, and shipbuilding sectors.
293 What will the “energy, shipping, and shipbuilding sectors of Iran” mean for the purposes of IFCA?
294 How will I know if someone is part of Iran’s energy, shipping, or shipbuilding sectors or is a port operator in Iran?
295 What are goods or services used in connection with Iran’s energy, shipping, or shipbuilding sectors for purposes of section 1244(d)(3)?
296 Will payment for bunkering of third-country ships carrying non-sanctionable goods to or from Iran be subject to sanctions?
297 Are there any exceptions to the sanctions provisions of section 1244 of IFCA?
315 Will routine payments or fees be subject to sanctions if they are made to a person determined to be a port operator in Iran and if the vessel is carrying non-sanctioned goods?
Sanctions Relating to the Sale, Supply, or Transfer of Certain Materials to or from Iran
IFCA provides for sanctions involving the sale, supply, or transfer of certain materials to or from Iran.
298 What materials are considered graphite, raw or semi-finished metals?
299 What are considered precious metals?
300 For purposes of sanctions under section 1245, how will I know which sectors are controlled by Iran’s Islamic Revolutionary Guard Corps?
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?
302 Are there any exceptions to section 1245 of IFCA?
Sanctions Relating to Insurance, Reinsurance, or Underwriting
303 Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under section 1246(a)(1)?
304 Are there exceptions to insuring, reinsuring, or underwriting sanctioned activities?
Sanctions Relating to FFIs that Facilitate Transactions with SDNs
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?
Executive Order
306 How does the Executive Order relate to the IFCA provisions?
307 In addition to implementing certain IFCA provisions, what else does the Executive Order do?
Sanctions Relating to the Provision of Material Assistance to Certain Persons
308 What are the implications of the material assistance provision of the Executive Order?
Sanctions Relating to Certain Transactions Involving the Iranian Rial
309 What transactions involving the Iranian rial will be subject to sanctions?
Sanctions Relating to Iran’s Automotive Sector
310 What is considered Iran’s automotive sector for purposes of the Executive Order?
311 What are goods or services used in connection with Iran’s automotive sector for purposes of the E.O.?
316 Is the sale, supply, or transfer of finished vehicles or “auto kits” to Iran sanctionable under the E.O.?
317 Is the sale, supply, or transfer of goods or services for the maintenance of finished vehicles sanctionable under the E.O.?
Financial Sanctions Relating to Financial Transactions on Behalf of Certain Persons
312 How does the Executive Order tighten the financial sanctions applicable to FFIs under section 1247 of IFCA?

 

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