Annex 134
Annex 134
Annex 134
Annex 136
Annex 136
Annex 137
Annex 137
Annex 137
Annex 138
Annex 138
Annex 138
Annex 138
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 1/10
U.S. Department of State
Diplomacy in Action
After the Deal: A New Iran Strategy
Remarks
Mike Pompeo
Secretary of State
The Heritage Foundation
Washington, DC
May 21, 2018
MS JAMES: Good morning. (Applause.) Welcome to the Heritage Foundation. My name is Kay James and I have the
honor of being the president here. It is a pleasure and honor to welcome our distinguished guest, Secretary of State Mike
Pompeo, back to Heritage. Yes, I said back. Some of you may remember that then-Congressman Pompeo spoke here on
September 9th, 2015. His presence was appreciated, as his topic was timely. It was entitled “A Pathway Forward: An
Alternative to the Flawed Iran Nuclear Deal.” And now we have the great pleasure of being with our friend in his new role
as Secretary of State for the United States of America. It’s not just a pleasure having him here; it’s truly an honor that he
chose Heritage as the site for his first public address as Secretary.
Our scholars here are dedicated to advancing individual freedom and national security, and his presence here is a wonderful
affirmation of the positive impact that their work is having. And so to Secretary Pompeo, I’d like to say thank you.
Now, I imagine all who are in this room and watching online know a great deal about Secretary Pompeo, but please allow me to
provide just a few highlights from his extraordinary career. Secretary Pompeo graduated first in his class at the United States
military academy at West Point, and then served as a cavalry officer patrolling the Iron Curtain before the fall of the Berlin Wall. He
also served with the 2nd Squadron, 7th Cavalry in the U.S. Army’s 4th Infantry Division. After leaving active duty, he attended and
graduated from Harvard Law School where he served as an editor of the Harvard Law Review. He then had a successful private
sector career, founding and serving as CEO of Thayer Aerospace and then becoming president of Sentry International.
Secretary Pompeo’s public service began when he was elected representative of Kansas’s 4th Congressional District, and his
distinguished tenure on the Hill included service on the House Intelligence Committee, the Energy and Commerce Committee, and
the House Select Benghazi Committee. Recognizing the Secretary’s many talents, President Trump tapped him as director of the
CIA, where he served from January 2017 to April 2018. And now, of course, he is our Secretary of State, having been sworn in just
three and a half weeks ago.
Last but, of course, never least, Secretary Pompeo is married to Susan Pompeo and has one son, Nick.
Secretary Pompeo, on behalf of the board of trustees, the staff, and all of the friends of the Heritage Foundation, welcome back to
home. (Applause.)
SECRETARY POMPEO: Well, good morning, everyone. I first want to thank the Heritage Foundation and its president, Kay Coles
James. Thank you for hosting me today. First as a private citizen and then as a member of Congress, and even today, the Heritage
Foundation has shaped my thinking on matters of the world and public policy issues. I’m grateful for that excellent work.
Annex 139
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 2/10
And thanks for reminding me I can’t talk about anything else but what we’re talking about today. (Laughter.) Three years on. But it’s
an honor to be here.
Two weeks ago, President Trump terminated the United States participation in the Joint Comprehensive Plan of Action, more
commonly known as the Iran nuclear deal.
President Trump withdrew from the deal for a simple reason: it failed to guarantee the safety of the American people from the risk
created by the leaders of the Islamic Republic of Iran.
No more. No more wealth creation for Iranian kleptocrats. No more acceptance of missiles landing in Riyadh and in the Golan
Heights. No more cost-free expansions of Iranian power. No more.
The JCPOA put the world at risk because of its fatal flaws.
And they’re worth recounting at some length today, if only for the purpose of ensuring that subsequent arrangements do not repeat
them.
For example, the weak sunset provisions of the JCPOA merely delayed the inevitable nuclear weapons capability of the Iranian
regime.
After the countdown clock ran out on the deal’s sunset provisions, Iran would be free for a quick sprint to the bomb, setting off a
potentially catastrophic arms race in the region. Indeed, the very brevity of the delay in the Iranian nuclear program itself
incentivized Middle Eastern proliferation.
Moreover, as we have seen from Israel’s recent remarkable intelligence operation, Iran has lied for years about having had a
nuclear weapons program. Iran entered into the JCPOA in bad faith. It is worth noting that even today, the regime continues to lie.
Just last month, Iranian Foreign Minister Zarif told a Sunday morning news show, “We never wanted to produce a bomb.”
This claim – this claim would be laughable if not for the willful deception behind it. Not only did the AMAD Program exist; the
Iranians took great care – though, as we can see now, not enough care – to protect, hide, and preserve the work of Mohsen
Fakhrizadeh Mahabadi and his gang of nuclear scientists.
The JCPOA had additional shortcomings as well.
The mechanisms for inspecting and verifying Iran’s compliance with the deal were simply not strong enough.
The deal did nothing to address Iran’s continuing development of ballistic and cruise missiles, which could deliver nuclear
warheads.
The JCPOA permitted the Iranian regime to use the money from the JCPOA to boost the economic fortunes of a struggling people,
but the regime’s leaders refused to do so.
Instead, the government spent its newfound treasure fueling proxy wars across the Middle East and lining the pockets of the
Islamic Revolutionary Guard Corps, Hizballah, Hamas, and the Houthis.
Remember: Iran advanced its march across the Middle East during the JCPOA. Qasem Soleimani has been playing with house
money that has become blood money. Wealth created by the West has fueled his campaigns.
Annex 139
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 3/10
Strategically, the Obama administration made a bet that the deal would spur Iran to stop its rogue state actions and conform to
international norms.
That bet was a loser with massive repercussions for all of the people living in the Middle East.
The idea of the JCPOA as a strategic pillar of stability in the Middle East was captured perfectly by John Kerry when he said, quote,
“I know the Middle East that is on fire … is going to be more manageable with this deal,” end of quote.
Query whether the Middle East is more manageable today than it was when they embarked on the JCPOA.
Lebanon is an even more comfortable home for Hizballah today than it was when we embarked on the JCPOA. Hizballah is now
armed to the teeth by Iran and has its sights set on Israel.
Thanks to Iran, Hizballah provides the ground forces for the military expedition in Syria. The IRGC, too, has continued to pump
thousands of fighters into Syria to prop up the murderous Assad regime and help make that country 71,000 square miles of kill
zone.
Iran perpetuates a conflict that has displaced more than 6 million Syrians inside the – 6 million Syrians and caused over 5 million to
seek refuge outside of its borders.
These refugees include foreign fighters who have crossed into Europe and threatened terrorist attacks in those countries.
In Iraq, Iran sponsored Shia militia groups and terrorists to infiltrate and undermine the Iraqi Security Forces and jeopardize Iraq’s
sovereignty – all of this during the JCPOA.
In Yemen, Iran’s support for the Houthi militia fuels a conflict that continues to starve the Yemeni people and hold them under the
threat of terror.
The IRGC has also given Houthi missiles to attack civilian targets in Saudi Arabia and the Emirates and to threaten international
shipping in the Red Sea.
And in Afghanistan, Iran’s support to the Taliban in the form of weapons and funding leads to further violence and hinders peace
and stability for the Afghan people.
Today, the Iranian Qods Force conducts covert assassination operations in the heart of Europe.
We should remember, too, that during the JCPOA Iran continues to hold Americans hostage: Baquer Namazi, Siamak Namazi,
Xiyue Wang, and Bob Levinson, who has been missing for over 11 years.
I will note for the American people, you should know we are working diligently to bring each American missing wrongfully detained
in Iran home.
The list continues. Iran continues to be, during the JCPOA, the world’s largest sponsor of terror. It continues to serve as sanctuary
for al-Qaida, as it has done since 9/11, and remains unwilling to bring to justice senior al-Qaida members residing in Tehran.
Today we ask the Iranian people: Is this what you want your country to be known for, for being a co-conspirator with Hizballah,
Hamas, the Taliban, and al-Qaida? The United States believe you deserve better.
Annex 139
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 4/10
And I have an additional point for the Iranian people to ponder. Here in the West, President Rouhani and Foreign Minister Zarif are
often held apart from the regime’s unwise terrorist and malign behavior. They are treated somehow differently.
The West says, “Boy, if only they could control Ayatollah Khamenei and Qasem Soleimani then things would be great.” Yet,
Rouhani and Zarif are your elected leaders. Are they not the most responsible for your economic struggles? Are these two not
responsible for wasting Iranian lives throughout the Middle East?
It’s worth the Iranian people considering, because instead of helping their own citizens, the regime continues to seek a corridor
stretching from Iran’s borders to the shores of the Mediterranean. Iran wants this corridor to transport fighters and an advanced
weapons system to Israel’s doorsteps. Indeed in recent months, the IRGC has flown an armed drone into Israeli airspace and
launched salvos of rockets into the Golan Heights from Syria. Our steadfast ally has asserted the sovereign right of self-defense in
response, a stance the United States will continue to unequivocally support.
So the bet – the bet that the JCPOA would increase Middle East stability was a bad one for America, for Europe, for the Middle
East, and indeed for the entire world. It is clear that the JCPOA has not ended Iran’s nuclear ambitions, nor did it deter its quest for
a regional hegemony. Iran’s leaders saw the deal as the starting gun for the march across the Middle East.
So, the path forward. America’s commitment to the Iran strategy President Trump laid down in October remains. It will now be
executed outside of the JCPOA.
We’ll continue to work with allies to counter the regime’s destabilizing activities in the region, block their financing of terror, and
address Iran’s proliferation of missiles and other advanced weapons systems that threaten peace and stability. We will also ensure
Iran has no path to a nuclear weapon – not now, not ever.
Following our withdrawal from the JCPOA, President Trump has asked me to achieve these goals on Iran. We’ll pursue those goals
along several lines of effort.
First, we will apply unprecedented financial pressure on the Iranian regime. The leaders in Tehran will have no doubt about our
seriousness.
Thanks to our colleagues at the Department of Treasury, sanctions are going back in full effect and new ones are coming. Last
week we imposed sanctions on the head of Iran’s central bank and other entities that were funneling money to the IRGC Qods
Force. They were also providing money to Hizballah and other terrorist organizations. The Iranian regime should know that this is
just the beginning.
This sting of sanctions will be painful if the regime does not change its course from the unacceptable and unproductive path it has
chosen to one that rejoins the league of nations. These will indeed end up being the strongest sanctions in history when we are
complete.
The regime has been fighting all over the Middle East for years. After our sanctions come in force, it will be battling to keep its
economy alive.
Iran will be forced to make a choice: either fight to keep its economy off life support at home or keep squandering precious wealth
on fights abroad. It will not have the resources to do both.
Second, I will work closely with the Department of Defense and our regional allies to deter Iranian aggression.
Annex 139
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 5/10
We will ensure freedom of navigation on the waters in the region. We will work to prevent and counteract any Iranian malign cyber
activity. We will track down Iranian operatives and their Hizballah proxies operating around the world and we will crush them. Iran
will never again have carte blanche to dominate the Middle East.
And I’d remind the leadership in Iran what President Trump said: If they restart their nuclear program, it will mean bigger problems –
bigger problems than they’d ever had before.
Third, we will also advocate tirelessly for the Iranian people. The regime must improve how it treats its citizens. It must protect the
human rights of every Iranian. It must cease wasting Iran’s wealth abroad.
We ask that our international partners continue to add their voice to ours in condemning Iran’s treatment of its own citizens.
The protests – the protests of the past few months show that the Iranian people are deeply frustrated with their own government’s
failures.
The Iranian economy is struggling as a result of bad Iranian decisions. Workers aren’t getting paid, strikes are a daily occurrence,
and the rial is plummeting. Youth unemployment is at a staggering 25 percent.
Government mismanagement of Iran’s natural resources has led to severe droughts and other environmental crises as well.
Look, these problems are compounded by enormous corruption inside of Iran, and the Iranian people can smell it. The protests last
winter showed that many are angry at the regime that keeps for itself what the regime steals from its people.
And Iranians too are angry at a regime elite that commits hundreds of millions of dollars to military operations and terrorist groups
abroad while the Iranian people cry out for a simple life with jobs and opportunity and with liberty.
The Iranian regime’s response to the protests has only exposed the country’s leadership is running scared. Thousands have been
jailed arbitrarily, and at least dozens have been killed.
As seen from the hijab protests, the brutal men of the regime seem to be particularly terrified by Iranian women who are demanding
their rights. As human beings with inherent dignity and inalienable rights, the women of Iran deserve the same freedoms that the
men of Iran possess.
But this is all on top of a well-documented terror and torture that the regime has inflicted for decades on those who dissent from the
regime’s ideology.
The Iranian regime is going to ultimately have to look itself in the mirror. The Iranian people, especially its youth, are increasingly
eager for economic, political, and social change.
The United States stands with those longing for a country of economic opportunity, government transparency, fairness, and greater
liberty.
We hope, indeed we expect, that the Iranian regime will come to its senses and support – not suppress – the aspirations of its own
citizens.
We’re open to new steps with not only our allies and partners, but with Iran as well. But only if Iran is willing to make major
changes.
Annex 139
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 6/10
As President Trump said two weeks ago, he is ready, willing, and able to negotiate a new deal. But the deal is not the objective. Our
goal is to protect the American people.
Any new agreement will make sure Iran never acquires a nuclear weapon, and will deter the regime’s malign behavior in a way that
the JCPOA never could. We will not repeat the mistakes of past administrations, and we will not renegotiate the JCPOA itself. The
Iranian wave of destruction in the region in just the last few years is proof that Iran’s nuclear aspirations cannot be separated from
the overall security picture.
So what should it be? We must begin to define what it is that we demand from Iran.
First, Iran must declare to the IAEA a full account of the prior military dimensions of its nuclear program, and permanently and
verifiably abandon such work in perpetuity.
Second, Iran must stop enrichment and never pursue plutonium reprocessing. This includes closing its heavy water reactor.
Third, Iran must also provide the IAEA with unqualified access to all sites throughout the entire country.
Iran must end its proliferation of ballistic missiles and halt further launching or development of nuclear-capable missile systems.
Iran must release all U.S. citizens, as well as citizens of our partners and allies, each of them detained on spurious charges.
Iran must end support to Middle East terrorist groups, including Lebanese Hizballah, Hamas, and the Palestinian Islamic Jihad.
Iran must respect the sovereignty of the Iraqi Government and permit the disarming, demobilization, and reintegration of Shia
militias.
Iran must also end its military support for the Houthi militia and work towards a peaceful political settlement in Yemen.
Iran must withdraw all forces under Iranian command throughout the entirety of Syria.
Iran, too, must end support for the Taliban and other terrorists in Afghanistan and the region, and cease harboring senior al-Qaida
leaders.
Iran, too, must end the IRG Qods Force’s support for terrorists and militant partners around the world.
And too, Iran must end its threatening behavior against its neighbors – many of whom are U.S. allies. This certainly includes its
threats to destroy Israel, and its firing of missiles into Saudi Arabia and the United Arab Emirates. It also includes threats to
international shipping and destructive – and destructive cyberattacks.
That list is pretty long, but if you take a look at it, these are 12 very basic requirements. The length of the list is simply a scope of
the malign behavior of Iran. We didn’t create the list, they did.
From my conversations with European friends, I know that they broadly share these same views of what the Iranian regime must do
to gain acceptance in the international community. I ask that America’s allies join us in calling for the Iranian Government to act
more responsibly.
In exchange for major changes in Iran, the United States is prepared to take actions which will benefit the Iranian people. These
areas of action include a number of things.
Annex 139
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 7/10
First, once this is achieved, we’re prepared to end the principal components of every one of our sanctions against the regime.
We’re happy at that point to re-establish full diplomatic and commercial relationships with Iran. And we’re prepared to admit[i] Iran
to have advanced technology. If Iran makes this fundamental strategic shift, we, too, are prepared to support the modernization and
reintegration of the Iranian economy into the international economic system.
But relief from our efforts will come only when we see tangible, demonstrated, and sustained shifts in Tehran’s policies. We
acknowledge Iran’s right to defend its people. But not its actions which jeopardize world’s citizens.
Also, in contrast to the previous administration, we want to include Congress as a partner in this process. We want our efforts to
have broad support with the American people and endure beyond the Trump Administration. A treaty would be our preferred way to
go.
Unlike the JCPOA, which was broadly rejected across both sides of the aisle, an agreement that President Trump proposes would
surely garner this type of widespread support from our elected leaders and the American people.
In the strategy we laid out today, we want the support of our most important allies and partners in the region and around the globe.
Certainly our European friends, but much more than that.
I want the Australians, the Bahrainis, the Egyptians, the Indians, the Japanese, the Jordanians, the Kuwaitis, the Omanis, the
Qataris, the Saudi Arabians, South Korea, the UAE, and many, many others worldwide to join in this effort against the Islamic
Republic of Iran. I know that those countries share the same goals. They understand the challenge the same way that America
does. Indeed, we welcome any nation which is sick and tired of the nuclear threats, the terrorism, the missile proliferation, and the
brutality of a regime which is at odds with world peace, a country that continues to inflict chaos on innocent people.
Indeed, while to some the changes in Iranian behavior we seek may seem unrealistic, we should recall that what we are pursuing
was the global consensus before the JCPOA.
For example, in 2012, President Obama said, quote, “The deal we’ll accept is [that] they end their nuclear program,” end of quote.
That didn’t happen. In 2006, the P5 voted at the Security Council for Iran to immediately suspend all enrichment activities. That
didn’t happen.
In 2013, the French foreign minister said he was wary of being sucked into a, quote, “con game,” end of quote, over allowing Iran to
continue uranium enrichment.
In 2015, John Kerry said, quote, “We don’t recognize the right to enrich,” end of quote. Yet the Iranians are enriching even as we sit
here today.
So we’re not asking anything other than that Iranian behavior be consistent with global norms, global norms widely recognized
before the JCPOA. And we want to eliminate their capacity to threaten our world with those nuclear activities.
With respect to its nuclear activities, why would we allow Iran more capability than we have permitted the United Arab Emirates and
that we’re asking for the Kingdom of Saudi Arabia? We understand that our reimposition of sanctions and the coming pressure
campaign on the Iranian regime will pose financial and economic difficulties for a number of our friends. Indeed, it imposes
economic challenges to America as well. These are markets our businesses would love to sell into as well. And we want to hear
their concerns.
But we will hold those doing prohibited business in Iran to account. Over the coming weeks, we will send teams of specialists to
countries around the world to further explain administration policy, to discuss the implications of sanctions we imposition, and to
listen.
Annex 139
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 8/10
I know. I’ve spent a great deal of time with our allies in my first three weeks. I know that they may decide to try and keep their old
nuclear deal going with Tehran. That is certainly their decision to make. They know where we stand.
Next year marks the 40th anniversary of the Islamic Republic – Revolution in Iran. At this milestone, we have to ask: What has the
Iranian Revolution given to the Iranian people? The regime reaps a harvest of suffering and death in the Middle East at the
expense of its own citizens. Iran’s economy is stagnant and without direction and about to get worse. Its young people are withering
under the weight of frustrated ambitions. They are longing to pursue the freedoms and opportunities of the 21st century.
Iran’s leaders can change all of this if they choose to do so. Ali Khamenei has been supreme leader since 1989. He will not live
forever, nor will the Iranian people abide the rigid rules of tyrants forever. For two generations, the Iranian regime has exacted a
heavy toll on its own people and the world. The hard grip of repression is all that millions of Iranians have ever known.
Now is the time for the supreme leader and the Iranian regime to summon the courage to do something historically beneficial for its
own people, for this ancient and proud nation.
As for the United States, our eyes are clear as to the nature of this regime, but our ears are open to what may be possible. Unlike
the previous administration, we are looking for outcomes that benefit the Iranian people, not just the regime.
If anyone, especially the leaders of Iran, doubts the President’s sincerity or his vision, let them look at our diplomacy with North
Korea. Our willingness to meet with Kim Jong-un underscores the Trump administration’s commitment to diplomacy to help solve
the greatest challenges, even with our staunchest adversaries. But that willingness, that willingness has been accompanied by a
painful pressure campaign that reflects our commitment to resolve this challenge forever.
To the ayatollah, to President Rouhani, and to other Iranian leaders: understand that your current activities will be met with steely
resolve.
My final message today is, in fact, to the Iranian people. I want to repeat President Trump’s words from October. President Trump
said that, “We stand in total solidarity with the Iranian regime’s longest-suffering victims: its own people. The citizens of Iran have
paid a heavy price for the violence and extremism of their leaders. The Iranian people long to reclaim their country’s proud history,
its culture, its civilization, and its cooperation with its neighbors.”
It is America’s hope that our labors toward peace and security will bear fruit for the long-suffering people of Iran. We long to see
them prosper and flourish as in past decades and, indeed, as never before.
Today, the United States of America is proud to take a new course towards that objective.
Thank you. (Applause.)
MS JAMES: Thank you so very much. Bold, concise, unambiguous. We appreciate you taking this forum here at the Heritage
Foundation to deliver that message. Looking at – and you listed during your speech several of our allies and friends and partners,
many of whom are angry, some disappointed. How are you going to bring them on board? How are you going to use your best
diplomatic skills to bring them along with us?
SECRETARY POMPEO: These strategic changes in the world come together when countries decide on an objective that is shared,
and that always begins with a shared interest and values. I spent the first couple of weeks of my time as Secretary of State working
to try to see if there wasn’t a way to fix the deal. I spoke with my European counterparts. I traveled there. In my 13th hour as
Secretary of State I was on the ground in Brussels speaking with my European counterparts. We couldn’t get it done. We couldn’t
reach agreement there.
Annex 139
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 9/10
The United States intends to work hard at the diplomatic piece of working alongside all of our partners. We focus on the Europeans,
but there are scores of countries around the world who share our concerns and are equally threatened by the Iranian regime. It’s
that shared interest, it’s the value set which will ultimately drive, I believe, a global response to this – to the world’s largest state
sponsor of terror. I’m convinced it can take place. My team is going to work diligently to do that. We’re going to do so in the context
of trying to address the concerns of all of our partners, and I am convinced that over a period of time there will be a broad
recognition that the strategy that President Trump has laid out is the right one that will put Iran in a place where it will one day rejoin
civilization in the way that we all hope that it will.
MS JAMES: It’s clear through your comments this morning that you truly want tough sanctions. And I think that there is some
remaining concern about how are you going to deal with the nuclear concerns. Can you speak to that for just a bit? And let me say
to our audience, by the way, that I wish we had more time with the Secretary this morning, and there will be an abrupt and a hard
stop because we have to get him out to the CIA and – for the swearing-in ceremony, and we don’t want you late for that.
So talk to us about --
SECRETARY POMPEO: I got to go back one more time.
MS JAMES: One more time. (Laughter.)
SECRETARY POMPEO: Look, the nuclear file is imperative. It presents the largest, most severe threat for sure. The JCPOA fell
short. It was a delay. Our aim is to get that permanently fixed. I mentioned quickly, right, we ask our other Middle Eastern partners
to do hard things. We put a 123 agreement in front of them and say, “This is what you have to do.” And they say, “Hey, the Iranians
enrich.” That’s reasonable. That seems to me a reasonable point.
Well, our demands on Iran aren’t unreasonable. Give up your program. End it. Should they choose to go back, should they begin to
enrich, we’re fully prepared to respond to that as well. I’m certainly not going to share with you today precisely what our response
will be. But we watch them talk. We’ve heard them say – I hope that they’ll make a different decision, that they’ll choose a different
path. We welcome them taking a path that other nations in the region are beginning to take as well.
MS JAMES: Well, can you explain for us the sanctions structure and how you intend to target the Iranian regime without hurting
our European friends?
SECRETARY POMPEO: Well, any time sanctions are put in place, countries have to give up economic activity. So the Americans
have given up economic activity now for an awfully long time, and I’ll concede there are American companies who would love to do
business with the Islamic Republic of Iran. There’s a huge market there. It’s a big, vibrant, wonderful peoples. But everyone is going
to have to participate in this. Every country is going to have to understand that we cannot continue to create wealth for Qasem
Soleimani.
Right, that’s what this is. At the end of the day, this money has flowed to him. The economics have permitted them to run roughshod
across the Middle East. Our effort is to strangle his economic capacity to do harm to the Middle East and to the world. Nuclear
programs aren’t cheap. To the extent we are effective at making it more difficult on the Iranian regime, we will reduce their capacity
to continue to build out their nuclear weapon system as well.
MS JAMES: You’ve laid out a very, very bold plan this morning. Do you have a timeframe for getting all this done?
SECRETARY POMPEO: So the sanctions are back in place and are winding down over the next 100 and what, 55 days? There are
– there’s lots more work in place. It is a effort across all of government. We are working certainly diplomatically in the lead, but
Department of Commerce, Department of Defense, each of us has the same mission from President Trump. I can’t put a timeline
Annex 139
8/20/2018 After the Deal: A New Iran Strategy
https://www.state.gov/secretary/remarks/2018/05/282301.htm 10/10
The Office of Website Management, Bureau of Public Affairs, manages this site as a portal for information from the U.S.
State Department.
External links to other Internet sites should not be construed as an endorsement of the views or privacy policies contained
therein.
Note: documents in Portable Document Format (PDF) require Adobe Acrobat Reader 5.0 or higher to view, download Adobe Acrobat
Reader (http://get.adobe.com/reader/).
on it. But at the end of the day, the Iranian people will decide the timeline. At the end of the day, the Iranian people will get to make
a choice about their leadership. If they make the decision quickly, that would be wonderful. If they choose not to do so, we will stay
hard at this until we achieve the outcomes that I set forward today.
MS JAMES: Well, Mr. Secretary, again, on behalf of the Heritage Foundation and the scholars here who have been working on
these issues for a very long time, we want to thank you. Again, it was a bold vision – clear, concise, unambiguous – and we want to
congratulate you and the President, and we wish you Godspeed.
I am going to ask you to remain seated while the Secretary exits. I have about eight more questions here, but --
SECRETARY POMPEO: For another day.
MS JAMES: For another day.
SECRETARY POMPEO: Thank you all very much for being here.
MS JAMES: Thank you so much. (Applause.)
Annex 139
8/20/2018 Remarks by President Trump on Iran Strategy
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 1/7
Diplomatic Reception Room
12:53 P.M. EDT
THE PRESIDENT: Thank you very much. My fellow Americans: As President of the United States, my
highest obligation is to ensure the safety and security of the American people.
History has shown that the longer we ignore a threat, the more dangerous that threat becomes. For
this reason, upon taking oice, I’ve ordered a complete strategic review of our policy toward the
rogue regime in Iran. That review is now complete.
Today, I am announcing our strategy, along with several major steps we are taking to confront the
Iranian regime’s hostile actions and to ensure that Iran never, and I mean never, acquires a nuclear
weapon.
Our policy is based on a clear-eyed assessment of the Iranian dictatorship, its sponsorship of
terrorism, and its continuing aggression in the Middle East and all around the world.
Iran is under the control of a fanatical regime that seized power in 1979 and forced a proud people
to submit to its extremist rule. This radical regime has raided the wealth of one of the world’s oldest
and most vibrant nations, and spread death, destruction, and chaos all around the globe.
REMARKS
Remarks by President Trump on Iran Strategy
NATIONAL SECURITY & DEFENSE
Issued on: October 13, 2017
★ ★ ★
Annex 140
8/20/2018 Remarks by President Trump on Iran Strategy
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 2/7
Beginning in 1979, agents of the Iranian regime illegally seized the U.S. embassy in Tehran and held
more than 60 Americans hostage during the 444 days of the crisis. The Iranian-backed terrorist
group Hezbollah twice bombed our embassy in Lebanon — once in 1983 and again in 1984. Another
Iranian-supported bombing killed 241 Americans — service members they were, in their barracks in
Beirut in 1983.
In 1996, the regime directed another bombing of American military housing in Saudi Arabia,
murdering 19 Americans in cold blood.
Iranian proxies provided training to operatives who were later involved in al Qaeda’s bombing of
the American embassies in Kenya, Tanzania, and two years later, killing 224 people, and wounding
more than 4,000 others.
The regime harbored high-level terrorists in the wake of the 9/11 attacks, including Osama bin
Laden’s son. In Iraq and Afghanistan, groups supported by Iran have killed hundreds of American
military personnel.
The Iranian dictatorship’s aggression continues to this day. The regime remains the world’s leading
state sponsor of terrorism, and provides assistance to al Qaeda, the Taliban, Hezbollah, Hamas, and
other terrorist networks. It develops, deploys, and proliferates missiles that threaten American
troops and our allies. It harasses American ships and threatens freedom of navigation in the
Arabian Gulf and in the Red Sea. It imprisons Americans on false charges. And it launches
cyberattacks against our critical infrastructure, financial system, and military.
The United States is far from the only target of the Iranian dictatorship’s long campaign of
bloodshed. The regime violently suppresses its own citizens; it shot unarmed student protestors in
the street during the Green Revolution.
This regime has fueled sectarian violence in Iraq, and vicious civil wars in Yemen and Syria. In Syria,
the Iranian regime has supported the atrocities of Bashar al-Assad’s regime and condoned Assad’s
use of chemical weapons against helpless civilians, including many, many children.
Given the regime’s murderous past and present, we should not take lightly its sinister vision for the
future. The regime’s two favorite chants are “Death to America” and “Death to Israel.”
Annex 140
8/20/2018 Remarks by President Trump on Iran Strategy
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 3/7
Realizing the gravity of the situation, the United States and the United Nations Security Council
sought, over many years, to stop Iran’s pursuit of nuclear weapons with a wide array of strong
economic sanctions.
But the previous administration lied these sanctions, just before what would have been the total
collapse of the Iranian regime, through the deeply controversial 2015 nuclear deal with Iran. This
deal is known as the Joint Comprehensive Plan of Action, or JCPOA.
As I have said many times, the Iran Deal was one of the worst and most one-sided transactions the
United States has ever entered into. The same mindset that produced this deal is responsible for
years of terrible trade deals that have sacrificed so many millions of jobs in our country to the
benefit of other countries. We need negotiators who will much more strongly represent America’s
interest.
The nuclear deal threw Iran’s dictatorship a political and economic lifeline, providing urgently
needed relief from the intense domestic pressure the sanctions had created. It also gave the regime
an immediate financial boost and over $100 billion dollars its government could use to fund
terrorism.
The regime also received a massive cash settlement of $1.7 billion from the United States, a large
portion of which was physically loaded onto an airplane and flown into Iran. Just imagine the sight
of those huge piles of money being hauled o by the Iranians waiting at the airport for the cash. I
wonder where all that money went.
Worst of all, the deal allows Iran to continue developing certain elements of its nuclear program.
And importantly, in just a few years, as key restrictions disappear, Iran can sprint towards a rapid
nuclear weapons breakout. In other words, we got weak inspections in exchange for no more than a
purely short-term and temporary delay in Iran’s path to nuclear weapons.
What is the purpose of a deal that, at best, only delays Iran’s nuclear capability for a short period of
time? This, as President of the United States, is unacceptable. In other countries, they think in
terms of 100-year intervals, not just a few years at a time.
The saddest part of the deal for the United States is that all of the money was paid up front, which is
unheard of, rather than at the end of the deal when they have shown they’ve played by the rules.
Annex 140
8/20/2018 Remarks by President Trump on Iran Strategy
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 4/7
But what’s done is done, and that’s why we are where we are.
Iranian regime has committed multiple violations of the agreement. For example, on two separate
occasions, they have exceeded the limit of 130 metric tons of heavy water. Until recently, the
Iranian regime has also failed to meet our expectations in its operation of advanced centrifuges.
The Iranian regime has also intimidated international inspectors into not using the full inspection
authorities that the agreement calls for.
Iranian oicials and military leaders have repeatedly claimed they will not allow inspectors onto
military sites, even though the international community suspects some of those sites were part of
Iran’s clandestine nuclear weapons program.
There are also many people who believe that Iran is dealing with North Korea. I am going to instruct
our intelligence agencies to do a thorough analysis and report back their findings beyond what
they have already reviewed.
By its own terms, the Iran Deal was supposed to contribute to “regional and international peace
and security.” And yet, while the United States adheres to our commitment under the deal, the
Iranian regime continues to fuel conflict, terror, and turmoil throughout the Middle East and
beyond. Importantly, Iran is not living up to the spirit of the deal.
So today, in recognition of the increasing menace posed by Iran, and aer extensive consultations
with our allies, I am announcing a new strategy to address the full range of Iran’s destructive
actions.
First, we will work with our allies to counter the regime’s destabilizing activity and support for
terrorist proxies in the region.
Second, we will place additional sanctions on the regime to block their financing of terror.
Third, we will address the regime’s proliferation of missiles and weapons that threaten its
neighbors, global trade, and freedom of navigation.
And finally, we will deny the regime all paths to a nuclear weapon.
Annex 140
8/20/2018 Remarks by President Trump on Iran Strategy
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 5/7
Today, I am also announcing several major steps my administration is taking in pursuit of this
strategy.
The execution of our strategy begins with the long-overdue step of imposing tough sanctions on
Iran’s Islamic Revolutionary Guard Corps. The Revolutionary Guard is the Iranian Supreme Leader’s
corrupt personal terror force and militia. It has hijacked large portions of Iran’s economy and seized
massive religious endowments to fund war and terror abroad. This includes arming the Syrian
dictator, supplying proxies and partners with missiles and weapons to attack civilians in the region,
and even plotting to bomb a popular restaurant right here in Washington, D.C.
I am authorizing the Treasury Department to further sanction the entire Islamic Revolutionary
Guard Corps for its support for terrorism and to apply sanctions to its oicials, agents, and
ailiates. I urge our allies to join us in taking strong actions to curb Iran’s continued dangerous and
destabilizing behavior, including thorough sanctions outside the Iran Deal that target the regime’s
ballistic missile program, in support for terrorism, and all of its destructive activities, of which there
are many.
Finally, on the grave matter of Iran’s nuclear program: Since the signing of the nuclear agreement,
the regime’s dangerous aggression has only escalated. At the same time, it has received massive
sanctions relief while continuing to develop its missiles program. Iran has also entered into
lucrative business contracts with other parties to the agreement.
When the agreement was finalized in 2015, Congress passed the Iran Nuclear Agreement Review Act
to ensure that Congress’s voice would be heard on the deal. Among other conditions, this law
requires the President, or his designee, to certify that the suspension of sanctions under the deal is
“appropriate and proportionate” to measure — and other measures taken by Iran to terminate its
illicit nuclear program. Based on the factual record I have put forward, I am announcing today that
we cannot and will not make this certification.
We will not continue down a path whose predictable conclusion is more violence, more terror, and
the very real threat of Iran’s nuclear breakout.
That is why I am directing my administration to work closely with Congress and our allies to
address the deal’s many serious flaws so that the Iranian regime can never threaten the world with
Annex 140
8/20/2018 Remarks by President Trump on Iran Strategy
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 6/7
nuclear weapons. These include the deal’s sunset clauses that, in just a few years, will eliminate key
restrictions on Iran’s nuclear program.
The flaws in the deal also include insuicient enforcement and near total silence on Iran’s missile
programs. Congress has already begun the work to address these problems. Key House and Senate
leaders are draing legislation that would amend the Iran Nuclear Agreement Review Act to
strengthen enforcement, prevent Iran from developing an inter- — this is so totally important — an
intercontinental ballistic missile, and make all restrictions on Iran’s nuclear activity permanent
under U.S. law. So important. I support these initiatives.
However, in the event we are not able to reach a solution working with Congress and our allies,
then the agreement will be terminated. It is under continuous review, and our participation can be
cancelled by me, as President, at any time.
As we have seen in North Korea, the longer we ignore a threat, the worse that threat becomes. It is
why we are determined that the world’s leading sponsor of terrorism will never obtain nuclear
weapons.
In this eort, we stand in total solidarity with the Iranian regime’s longest-suering victims: its own
people. The citizens of Iran have paid a heavy price for the violence and extremism of their leaders.
The Iranian people long to — and they just are longing, to reclaim their country’s proud history, its
culture, its civilization, its cooperation with its neighbors.
We hope that these new measures directed at the Iranian dictatorship will compel the government
to reevaluate its pursuit of terror at the expense of its people.
We hope that our actions today will help bring about a future of peace, stability, and prosperity in
the Middle East –- a future where sovereign nations respect each other and their own citizens.
We pray for a future where young children — American and Iranian, Muslim, Christian, and Jewish
— can grow up in a world free from violence, hatred, and terror.
And, until that blessed day comes, we will do what we must to keep America safe.
Thank you, God bless you, and God bless America. Thank you.
Annex 140
8/20/2018 Remarks by President Trump on Iran Strategy
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 7/7
END
1:11 P.M. EDT
Annex 140
8/20/2018 Remarks by President Trump on the Joint Comprehensive Plan of Action
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 1/5
Diplomatic Reception Room
2:13 P.M. EDT
THE PRESIDENT: My fellow Americans: Today, I want to update the world on our eorts to prevent
Iran from acquiring a nuclear weapon.
The Iranian regime is the leading state sponsor of terror. It exports dangerous missiles, fuels
conflicts across the Middle East, and supports terrorist proxies and militias such as Hezbollah,
Hamas, the Taliban, and al Qaeda.
Over the years, Iran and its proxies have bombed American embassies and military installations,
murdered hundreds of American servicemembers, and kidnapped, imprisoned, and tortured
American citizens. The Iranian regime has funded its long reign of chaos and terror by plundering
the wealth of its own people.
No action taken by the regime has been more dangerous than its pursuit of nuclear weapons and
the means of delivering them.
In 2015, the previous administration joined with other nations in a deal regarding Iran’s nuclear
program. This agreement was known as the Joint Comprehensive Plan of Action, or JCPOA.
REMARKS
Remarks by President Trump on the Joint
Comprehensive Plan of Action
FOREIGN POLICY
Issued on: May 8, 2018
★ ★ ★
Annex 141
8/20/2018 Remarks by President Trump on the Joint Comprehensive Plan of Action
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 2/5
In theory, the so-called “Iran deal” was supposed to protect the United States and our allies from
the lunacy of an Iranian nuclear bomb, a weapon that will only endanger the survival of the Iranian
regime. In fact, the deal allowed Iran to continue enriching uranium and, over time, reach the brink
of a nuclear breakout.
The deal lied crippling economic sanctions on Iran in exchange for very weak limits on the
regime’s nuclear activity, and no limits at all on its other malign behavior, including its sinister
activities in Syria, Yemen, and other places all around the world.
In other words, at the point when the United States had maximum leverage, this disastrous deal
gave this regime — and it’s a regime of great terror — many billions of dollars, some of it in actual
cash — a great embarrassment to me as a citizen and to all citizens of the United States.
A constructive deal could easily have been struck at the time, but it wasn’t. At the heart of the Iran
deal was a giant fiction that a murderous regime desired only a peaceful nuclear energy program.
Today, we have definitive proof that this Iranian promise was a lie. Last week, Israel published
intelligence documents long concealed by Iran, conclusively showing the Iranian regime and its
history of pursuing nuclear weapons.
The fact is this was a horrible, one-sided deal that should have never, ever been made. It didn’t
bring calm, it didn’t bring peace, and it never will.
In the years since the deal was reached, Iran’s military budget has grown by almost 40 percent,
while its economy is doing very badly. Aer the sanctions were lied, the dictatorship used its new
funds to build nuclear-capable missiles, support terrorism, and cause havoc throughout the Middle
East and beyond.
The agreement was so poorly negotiated that even if Iran fully complies, the regime can still be on
the verge of a nuclear breakout in just a short period of time. The deal’s sunset provisions are
totally unacceptable. If I allowed this deal to stand, there would soon be a nuclear arms race in the
Middle East. Everyone would want their weapons ready by the time Iran had theirs.
Making matters worse, the deal’s inspection provisions lack adequate mechanisms to prevent,
detect, and punish cheating, and don’t even have the unqualified right to inspect many important
Annex 141
8/20/2018 Remarks by President Trump on the Joint Comprehensive Plan of Action
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 3/5
locations, including military facilities.
Not only does the deal fail to halt Iran’s nuclear ambitions, but it also fails to address the regime’s
development of ballistic missiles that could deliver nuclear warheads.
Finally, the deal does nothing to constrain Iran’s destabilizing activities, including its support for
terrorism. Since the agreement, Iran’s bloody ambitions have grown only more brazen.
In light of these glaring flaws, I announced last October that the Iran deal must either be
renegotiated or terminated.
Three months later, on January 12th, I repeated these conditions. I made clear that if the deal
could not be fixed, the United States would no longer be a party to the agreement.
Over the past few months, we have engaged extensively with our allies and partners around the
world, including France, Germany, and the United Kingdom. We have also consulted with our
friends from across the Middle East. We are unified in our understanding of the threat and in our
conviction that Iran must never acquire a nuclear weapon.
Aer these consultations, it is clear to me that we cannot prevent an Iranian nuclear bomb under
the decaying and rotten structure of the current agreement.
The Iran deal is defective at its core. If we do nothing, we know exactly what will happen. In just a
short period of time, the world’s leading state sponsor of terror will be on the cusp of acquiring the
world’s most dangerous weapons.
Therefore, I am announcing today that the United States will withdraw from the Iran nuclear deal.
In a few moments, I will sign a presidential memorandum to begin reinstating U.S. nuclear
sanctions on the Iranian regime. We will be instituting the highest level of economic sanction. Any
nation that helps Iran in its quest for nuclear weapons could also be strongly sanctioned by the
United States.
America will not be held hostage to nuclear blackmail. We will not allow American cities to be
threatened with destruction. And we will not allow a regime that chants “Death to America” to gain
Annex 141
8/20/2018 Remarks by President Trump on the Joint Comprehensive Plan of Action
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 4/5
access to the most deadly weapons on Earth.
Today’s action sends a critical message: The United States no longer makes empty threats. When I
make promises, I keep them. In fact, at this very moment, Secretary Pompeo is on his way to North
Korea in preparation for my upcoming meeting with Kim Jong-un. Plans are being made.
Relationships are building. Hopefully, a deal will happen and, with the help of China, South Korea,
and Japan, a future of great prosperity and security can be achieved for everyone.
As we exit the Iran deal, we will be working with our allies to find a real, comprehensive, and lasting
solution to the Iranian nuclear threat. This will include eorts to eliminate the threat of Iran’s
ballistic missile program; to stop its terrorist activities worldwide; and to block its menacing activity
across the Middle East. In the meantime, powerful sanctions will go into full eect. If the regime
continues its nuclear aspirations, it will have bigger problems than it has ever had before.
Finally, I want to deliver a message to the long-suering people of Iran: The people of America
stand with you. It has now been almost 40 years since this dictatorship seized power and took a
proud nation hostage. Most of Iran’s 80 million citizens have sadly never known an Iran that
prospered in peace with its neighbors and commanded the admiration of the world.
But the future of Iran belongs to its people. They are the rightful heirs to a rich culture and an
ancient land. And they deserve a nation that does justice to their dreams, honor to their history,
and glory to God.
Iran’s leaders will naturally say that they refuse to negotiate a new deal; they refuse. And that’s
fine. I’d probably say the same thing if I was in their position. But the fact is they are going to want
to make a new and lasting deal, one that benefits all of Iran and the Iranian people. When they do, I
am ready, willing, and able.
Great things can happen for Iran, and great things can happen for the peace and stability that we all
want in the Middle East.
There has been enough suering, death, and destruction. Let it end now.
Thank you. God bless you. Thank you.
Annex 141
8/20/2018 Remarks by President Trump on the Joint Comprehensive Plan of Action
https://www.whitehouse.gov/briefings-statements/remarks-president-trump… 5/5
(The presidential memorandum is signed.)
Q Mr. President, how does this make America safer? How does this make America safer?
THE PRESIDENT: Thank you very much. This will make America much safer. Thank you very much.
Q Is Secretary Pompeo bringing the detainees home?
THE PRESIDENT: Thank you. Secretary Pompeo is, right now, going to North Korea. He will be
there very shortly in a matter of virtual — probably an hour. He’s got meetings set up. We have our
meeting scheduled. We have our meeting set. The location is picked — the time and the date.
Everything is picked. And we look forward to having a very great success.
We think relationships are building with North Korea. We’ll see how it all works out. Maybe it will,
maybe it won’t. But it can be a great thing for North Korea, South Korea, Japan and the entire
world. We hope it all works out.
Thank you very much.
Q Are the Americans being freed?
Q Are the Americans coming home, Mr. President?
THE PRESIDENT: We’ll all soon be finding out. We will soon be finding out. It would be a great
thing if they are. We’ll soon be finding out. Thank you very much.
END
2:25 P.M. EDT
Annex 141
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Annex 143
Issued on May 8, 2018
Last Updated on August 6, 2018
1
This document is explanatory only and does not have the force of law. Please see particularly
the legally binding provisions cited below governing the sanctions. This document does not
supplement or modify the statutory authorities, Executive orders, or regulations.
Frequently Asked Questions Regarding the Re-Imposition of Sanctions Pursuant to the
May 8, 2018 National Security Presidential Memorandum Relating to
the Joint Comprehensive Plan of Action (JCPOA)
1. GENERAL QUESTIONS
1.1. Effective May 8, 2018, what sanctions snap back into place?
On May 8, 2018, the President announced his decision to cease the United States’
participation in the Joint Comprehensive Plan of Action (JCPOA), and to begin reimposing,
following a wind-down period, the U.S. nuclear-related sanctions that were
lifted to effectuate the JCPOA sanctions relief. In conjunction with this announcement,
the President issued a National Security Presidential Memorandum (NSPM) directing the
Secretary of State and the Secretary of the Treasury to prepare immediately for the reimposition
of all of the U.S. sanctions lifted or waived in connection with the JCPOA, to
be accomplished as expeditiously as possible and in no case later than 180 days from the
date of the NSPM.
To implement the President’s direction, the Departments of State and of the Treasury will
take steps necessary to establish a 90-day and a 180-day wind-down period for activities
involving Iran that were consistent with the U.S. sanctions relief provided for under the
JCPOA. FAQs 1.2. and 1.3. below set out in further detail which sanctions will be reimposed
in which time frame.
Pursuant to the NSPM, the State Department revoked certain statutory waivers issued to
implement the JCPOA sanctions relief, issued the necessary statutory sanctions waivers
to provide for a wind-down period, and plans to take appropriate action to keep such
waivers in place for the duration of the relevant wind-down periods. Following
November 4, 2018, OFAC expects that all the U.S. nuclear-related sanctions that had
been lifted under the JCPOA will be re-imposed and in full effect.
Persons engaging in activity undertaken pursuant to the U.S. sanctions relief provided for
in the JCPOA should take the steps necessary to wind down those activities by either
August 6, 2018, or November 4, 2018, as applicable, to avoid exposure to sanctions or an
enforcement action under U.S. law. [05-08-2018]
1.2. Which sanctions will be re-imposed after the 90-day wind-down period ending
on August 6, 2018?
After the 90-day wind down period ends on August 6, 2018, the U.S. government will reimpose
the following sanctions that were lifted pursuant to the JCPOA, including
sanctions on associated services related to the activities below:
i. Sanctions on the purchase or acquisition of U.S. dollar banknotes by the
Government of Iran;
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
2
ii. Sanctions on Iran’s trade in gold or precious metals;
iii. Sanctions on the direct or indirect sale, supply, or transfer to or from Iran of
graphite, raw, or semi-finished metals such as aluminum and steel, coal, and
software for integrating industrial processes;
iv. Sanctions on significant transactions related to the purchase or sale of Iranian
rials, or the maintenance of significant funds or accounts outside the territory of
Iran denominated in the Iranian rial;
v. Sanctions on the purchase, subscription to, or facilitation of the issuance of
Iranian sovereign debt; and
vi. Sanctions on Iran’s automotive sector.
In addition, following the 90-day wind-down period that ends on August 6, 2018, the
U.S. government will revoke the following JCPOA-related authorizations under U.S.
primary sanctions regarding Iran:
i. The importation into the United States of Iranian-origin carpets and foodstuffs
and certain related financial transactions pursuant to general licenses under the
Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR);
ii. Activities undertaken pursuant to specific licenses issued in connection with the
Statement of Licensing Policy for Activities Related to the Export or Re-export to
Iran of Commercial Passenger Aircraft and Related Parts and Services (JCPOA
SLP); and
iii. Activities undertaken pursuant to General License I relating to contingent
contracts for activities eligible for authorization under the JCPOA SLP.
Persons engaging in the activities listed above undertaken pursuant to the U.S. sanctions
relief provided for in the JCPOA should take the steps necessary to wind down those
activities by August 6, 2018, to avoid exposure to sanctions or an enforcement action
under U.S. law. (See FAQ 2.1. below for a description of activities that would not be
prohibited or sanctionable during the wind-down period). [05-08-2018]
1.3. Which sanctions will be re-imposed after the 180-day wind-down period ending
on November 4, 2018?
Following the 180-day wind-down period ending on November 4, 2018, the U.S.
government will re-impose the following sanctions that were lifted pursuant to the
JCPOA, including sanctions on associated services related to the activities below:
i. Sanctions on Iran’s port operators, and shipping and shipbuilding sectors,
including on the Islamic Republic of Iran Shipping Lines (IRISL), South Shipping
Line Iran, or their affiliates;
ii. Sanctions on petroleum-related transactions with, among others, the National
Iranian Oil Company (NIOC), Naftiran Intertrade Company (NICO), and National
Iranian Tanker Company (NITC), including the purchase of petroleum, petroleum
products, or petrochemical products from Iran;
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
3
iii. Sanctions on transactions by foreign financial institutions with the Central Bank
of Iran and designated Iranian financial institutions under Section 1245 of the
National Defense Authorization Act for Fiscal Year 2012 (NDAA);
iv. Sanctions on the provision of specialized financial messaging services to the
Central Bank of Iran and Iranian financial institutions described in Section
104(c)(2)(E)(ii) of the Comprehensive Iran Sanctions and Divestment Act of 2010
(CISADA);
v. Sanctions on the provision of underwriting services, insurance, or reinsurance;
and
vi. Sanctions on Iran’s energy sector.
In addition, effective November 5, 2018, the U.S. government will revoke the
authorization for U.S.-owned or -controlled foreign entities to wind down certain
activities with the Government of Iran or persons subject to the jurisdiction of the
Government of Iran that were previously authorized pursuant to General License H. (See
FAQ 4.4. below).
Furthermore, no later than November 5, 2018, the U.S. government will re-impose, as
appropriate, the sanctions that applied to persons removed from the List of Specially
Designated Nationals and Blocked Persons (SDN List) and/or other lists maintained by
the U.S. government on January 16, 2016.
Persons engaging in the activity listed above undertaken pursuant to the U.S. sanctions
relief provided for in the JCPOA should take the steps necessary to wind down those
activities by November 4, 2018, to avoid exposure to sanctions or an enforcement action
under U.S. law. (See FAQ 2.1. below for a description of activities that would not be
prohibited or sanctionable during the wind-down period.) [05-08-2018]
1.4. Are the sanctions lifted via Executive Order 13716 reinstated as of August 7,
2018?
Executive Order of August 6, 2018, “Reimposing Certain Sanctions With Respect to
Iran” (the “New Iran E.O.”) reimposes relevant provisions of E.O.s 13574, 13590, 13622,
and 13645 that were revoked by E.O. 13716 at the end of the applicable wind-down
period (i.e., on or after August 7, 2018, or on or after November 5, 2018, depending on
the activity involved). In addition, to provide clarity and consolidate relevant authorities
into a single document, the New Iran E.O. revokes E.O.s 13716 and 13628 and continues
in effect certain sanctions authorities provided for in those E.O.s. [08-06-2018]
1.5. Do the FAQs and Guidance posted on OFAC’s website relating to the JCPOA
sanctions relief remain in effect?
As noted above, the President has directed the Secretaries of State and of the Treasury to
re-impose U.S. sanctions that were lifted or waived to effectuate the JCPOA sanctions
relief as set out in sections II, III, IV, and V of the Guidance Document at the end of the
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
4
applicable wind-down period. Furthermore, although the sanctions waivers described in
section VI of the Guidance Document are no longer in place, they have been replaced
with waivers that will allow for the orderly wind-down of activities as specified above.
Persons engaging in activity undertaken pursuant to the U.S. sanctions relief provided for
in the JCPOA should take the steps necessary to wind down their activities between May
8, 2018 and August 6, 2018, or between May 8, 2018 and November 4, 2018, as
applicable, to avoid exposure to sanctions or an enforcement action under U.S. law. The
JCPOA Guidance and JCPOA FAQs issued on January 16, 2016, as amended, remain
available on OFAC’s website only to assist persons in determining which activities were
not sanctionable or prohibited between January 16, 2016 and May 8, 2018, and to
determine how best to wind down such activity. To the extent there are inconsistencies
between the JCPOA FAQs, including guidance on wind-down, and other guidance
provided by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing. [05-08-2018]
2. WIND-DOWN
2.1. How long is the wind-down period and what types of activities are allowed?
The U.S. government has a past practice of working with U.S. or third-country
companies to minimize the impact of sanctions on the legitimate activities of those
parties undertaken prior to the imposition of sanctions.
To implement the May 8, 2018 NSPM, the Departments of State and of the Treasury will
establish a 90-day and a 180-day wind-down period, as applicable, for activities
involving Iran that were consistent with the U.S. sanctions lifting under the JCPOA. (See
FAQs 1.2. and 1.3. above for a list of activities subject to the 90- day or 180-day winddown
period.)
Consistent with this guidance from the President, the Department of State has revoked
certain statutory waivers issued to implement the JCPOA sanctions relief, issued the
necessary sanctions waivers to provide for an appropriate wind-down period, and plans to
take appropriate action to keep such waivers in place for the duration of the relevant
wind-down period, i.e., until August 6, 2018, or November 4, 2018, depending on the
activity. Non-U.S., non-Iranian persons are advised to use these time periods to winddown
their activities with or involving Iran that will become sanctionable at the end of
the applicable wind-down period.
In the event that a non-U.S, non-Iranian person is owed payment after the conclusion of
the wind-down period on August 6, 2018, or November 4, 2018, as applicable, for goods
or services fully provided or delivered to an Iranian counterparty prior to August 6, 2018,
or November 4, 2018, as applicable, pursuant to a written contract or written agreement
entered into prior to May 8, 2018, and such activities were consistent with U.S. sanctions
in effect at the time of delivery or provision, the U.S. government would allow the non-
U.S., non-Iranian person to receive payment for those goods or services according to the
terms of the written contract or written agreement. Similarly, if a non-U.S., non-Iranian
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
5
person is owed repayment after August 6, 2018, or November 4, 2018, as applicable, for
loans or credits extended to an Iranian counterparty prior to the end of the 90-day or 180-
day wind-down period, as applicable, provided that such loans or credits were extended
pursuant to a written contract or written agreement entered into prior to May 8, 2018, and
such activities were consistent with U.S. sanctions in effect at the time the loans or
credits were extended, the U.S. government would allow the non-U.S., non-Iranian
person to receive repayment of the related debt or obligation according to the terms of the
written contract or written agreement. This allowance is designed for non-U.S., non-
Iranian parties to be made whole for debts and obligations owed or due to them for goods
or services fully provided or delivered or loans or credit extended to an Iranian party
prior to the end of the 90-day or 180-day wind-down period, as applicable. Any
payments would need to be consistent with U.S. sanctions, including that payments could
not involve U.S. persons or the U.S. financial system, unless the transactions are exempt
from regulation or authorized by OFAC.
Consistent with the conditions described above, OFAC will take steps to allow U.S.
persons and U.S.-owned or -controlled foreign entities until August 6, 2018, or
November 4, 2018, as applicable, to wind down operations in or business involving Iran
conducted pursuant to an OFAC authorization, and to receive payments according to the
terms of the written contract or written agreement entered into prior to May 8, 2018, for
goods or services fully provided or delivered pursuant to an OFAC authorization. As
soon as administratively feasible, OFAC intends, via Federal Register publication, to
replace General License H, General License I, and the general licenses set forth at 31
C.F.R. §§ 560.534 and 560.535 (relating to trade in Iranian-origin carpets and foodstuffs)
with more narrowly scoped authorizations to allow U.S. persons and, as appropriate,
U.S.-owned or -controlled foreign entities, to engage in all transactions ordinarily
incident and necessary to wind down activities that were previously authorized pursuant
to General License H, General License I, or the general licenses set forth at 31 C.F.R.
§§ 560.534 and 560.535 and to receive payments according to the terms of the written
contract or written agreement entered into prior to May 8, 2018, for goods or services
fully provided or delivered pursuant to an OFAC authorization.
The provision or delivery of additional goods or services and/or the extension of
additional loans or credits to an Iranian counterparty after August 6, 2018, or November
4, 2018, as applicable, including pursuant to written contracts or written agreements
entered into prior to May 8, 2018, may result in the imposition of U.S. sanctions unless
such activities are exempt from regulation, authorized by OFAC, or otherwise not
sanctionable.
The U.S. government would evaluate matters falling outside the above parameters on a
case-by-case basis.
See FAQs 1.2. and 1.3. above for a list of activities subject to the 90-day or 180-day
wind-down period. [05-08-2018]
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
6
2.2. Can I engage in new activity involving Iran if the activity will not extend
beyond the end of the relevant wind-down period?
At the end of the wind-down periods, the State Department does not expect to issue
further broad waivers of relevant statutory authorities, and OFAC plans to revoke the
general and specific licenses issued in connection with the sanctions relief provided under
the JCPOA that may remain in effect as of that time. (See FAQs 4.1.-4.5. for more
details on the wind-down approach for general and specific licenses.) Prior to August 6,
2018, or November 4, 2018, as applicable, persons engaging in activity consistent with
the U.S. sanctions relief specified in the JCPOA should take the steps necessary to wind
down operations by that date to avoid exposure to sanctions or an enforcement action
when the applicable wind-down period ends. When considering a potential enforcement
or sanctions action with respect to activities engaged in after August 6, 2018, or
November 4, 2018, as applicable, OFAC will evaluate efforts and steps taken to wind
down activities and will assess whether any new business was entered into involving Iran
during the applicable wind-down period. [05-08-2018]
2.3 Under what circumstances are goods or services considered “fully provided or
delivered” prior to the expiration of the relevant wind-down period, as
referenced in FAQ 2.1 above?
OFAC looks to the industry standard to determine whether particular goods or services
are considered fully provided or delivered prior to the expiration of the relevant winddown
period. As a general matter, goods or services will be considered fully provided or
delivered when the party providing or delivering the goods or services has performed all
the actions and satisfied all the obligations necessary to be eligible for payment or other
agreed-to compensation. With respect to goods exported to or from Iran, at a minimum,
title to the goods must have transferred to the relevant party. [08-06-2018]
2.4 Can I, as a non-U.S., non-Iranian person, receive payments after the relevant
wind-down period ends for goods or services that were fully provided or
delivered during the relevant wind-down period pursuant to contracts entered
into prior to May 8, 2018?
Yes, subject to the conditions set out below and in FAQ 2.1 above, non-U.S., non-Iranian
persons may receive payment after the end of the relevant wind-down period for goods or
services fully provided or delivered to an Iranian counterparty prior to expiration of the
relevant wind-down period (see FAQ 2.3 above). In particular, the goods or services
must have been fully provided or delivered prior to the end of the applicable wind-down
period pursuant to a written contract or written agreement entered into prior to May 8,
2018; the relevant activities must have been consistent with U.S. sanctions in effect at the
time of delivery or provision, including that the activities did not involve persons on the
SDN List at the time of the transaction; and any payments must be consistent with U.S.
sanctions, including that payments can not involve U.S. persons or the U.S. financial
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
7
system, unless the transactions are exempt from regulation or authorized by OFAC. [08-
06-2018]
2.5 Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive
payments after the relevant wind-down period ends for goods or services that were
fully provided or delivered during the relevant wind-down period under an OFAC
wind-down authorization and pursuant to a contract entered into prior to May 8,
2018?
The wind-down authorizations allow U.S. persons and U.S.-owned or -controlled foreign
entities to receive payments for activities conducted pursuant to such wind-down
authorizations only during their validity periods. For example, a U.S.-owned or -
controlled foreign entity may receive payment through 11:59 p.m. eastern standard time
on November 4, 2018 for Iran-related activities undertaken pursuant to section 560.537 of
the ITSR (winding down of transactions relating to U.S.-owned or -controlled foreign
entities).
Any payment following the end of the relevant wind-down period for activities
undertaken pursuant to a wind-down authorization, including from an Iranian
counterparty, would require specific authorization from OFAC. OFAC will evaluate
such requests for specific licenses on a case-by-case basis.
Any request for a specific license should provide sufficient details for OFAC to evaluate
the application, including: whether the relevant transactions complied with U.S.
sanctions as in effect at the time of the transactions; whether the activities were
performed under a written contract or written agreement entered into prior to May 8,
2018; and why the applicant was unable to receive the payment for which authorization is
sought prior to the end of the relevant wind-down period. OFAC will generally deny
requests to receive payment for activities that were not authorized under the relevant
wind-down authorizations or that were not undertaken pursuant to a written contract or
written agreement entered into prior to May 8, 2018. [08-06-2018]
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
8
2.6 Can I enter into a new contract or engage in new business activity during the
relevant wind-down period that is in furtherance of a contract entered into prior to
May 8 and is ordinarily incident and necessary to the wind down of Iran-related
business? For example, is it sanctionable if a new purchase order is entered into
during the wind-down period if such business is contemplated under a Master
Services Agreement entered into prior to May 8?
Provided that the new contract or business is in furtherance of, a written contract or
written agreement entered into prior to May 8, 2018, and is necessary and ordinarily
incident to the wind down of activities under the pre-May 8, 2018 written contract or
written agreement, generally, OFAC would not consider entering into such new contracts
during the relevant wind-down period to be sanctionable as new business. OFAC will
evaluate matters falling outside these parameters on a case-by-case basis to determine
whether the activity is sanctionable or violates OFAC regulations. [08-06-2018]
2.7 Is it sanctionable for non-U.S., non-Iranian persons to engage in transactions
related to the provision of humanitarian and consumer goods to Iran?
The U.S. maintains broad authorizations and exceptions under U.S. sanctions that allow
for the sale of agricultural commodities, food, medicine, and medical devices to Iran by
U.S. persons and non-U.S. persons. Broadly speaking, transactions for the sale of
agricultural commodities, food, medicine, or medical devices to Iran are not sanctionable
unless they involve certain persons on the SDN List, including designated Iranian
financial institutions or the Islamic Revolutionary Guard Corps (IRGC), or otherwise
sanctionable conduct. Additional guidance relating to these authorizations and
exceptions can be found on the OFAC website here [hyperlink to
https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/iran_guidance_med.pdf] and here [hyperlink to
https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/hum_exp_iran.pdf].
Transactions by non-U.S. persons related to the export to Iran of consumer goods that do
not fall within these exceptions, but are not expressly targeted by U.S. sanctions should
not involve persons on the SDN List, including designated Iranian financial institutions
or the IRGC. In addition, such transactions should not involve U.S. persons or transit the
U.S. financial system, unless the activities and/or transactions are exempt from regulation
or authorized by OFAC. [08-06-2018]
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
9
3. SANCTIONS LISTINGS
3.1. Will the persons that were placed on the List of Persons Identified as Blocked
Solely Pursuant to Executive Order 13599 (E.O. 13599 List) on JCPOA
Implementation Day (January 16, 2016) be put back on the SDN List?
No later than November 5, 2018, OFAC expects to move persons identified as meeting
the definition of the terms “Government of Iran” or “Iranian financial institution” from
the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) to the
SDN List. OFAC will not add these persons to the SDN List on May 8, 2018, to allow
for the orderly wind down by non-U.S., non-Iranian persons of activities that had been
undertaken prior to May 8, 2018, consistent with the U.S. sanctions relief provided for
under the JCPOA involving persons on the E.O. 13599 List. The Government of Iran and
Iranian financial institutions remain persons whose property and interests in property are
blocked pursuant to E.O. 13599 and section 560.211 of the ITSR, and U.S. persons
continue to be broadly prohibited from engaging in transactions or dealing with the
Government of Iran and Iranian financial institutions. Beginning on November 5, 2018,
activities with most persons moved from the E.O. 13599 List to the SDN List will be
subject to secondary sanctions. Such persons will have a notation of “Additional
Sanctions Information – Subject to Secondary Sanctions” in their SDN List entry.
The United States has and continues to enforce multiple authorities that target a range of
Iranian malign activity outside of Iran’s nuclear program, including Iran’s support for
terrorism, ballistic missile program, human rights abuses, and destabilizing activity in the
region. Treasury will continue to target aggressively anyone who engages in such
sanctionable activity, regardless of whether the individual or entity was removed from the
SDN List on Implementation Day. [05-08-2018]
3.2. As of May 8, 2018, do secondary sanctions attach to the persons that were
removed from the SDN List and/or other OFAC sanctions lists on
Implementation Day?
No. However, no later than November 5, 2018, OFAC will re-impose, as appropriate, the
sanctions that applied to persons removed from the SDN List and/or other lists
maintained by OFAC on January 16, 2016. Depending on the authority or authorities
pursuant to which these actions to re-list are taken, there may be secondary sanctions
exposure for parties that engage in certain activities with these persons after their relisting.
Persons subject to secondary sanctions will have a notation of “Additional
Sanctions Information – Subject to Secondary Sanctions” in their SDN List entry.
Transactions conducted during the wind-down periods involving persons removed from
the SDN List on January 16, 2016 could be sanctionable to the extent they are outside the
scope of the wind-down waivers issued by the State Department or involve persons on
the SDN List or conduct described in JCPOA FAQ A.3.ii-iii. OFAC recommends that a
person conducting activities in Iran or with Iranian persons during the wind-down periods
exercise due diligence sufficient to ensure that it is not knowingly engaging in
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
10
transactions with persons on the SDN List or in activities that would be sanctionable
under authorities targeting Iran’s malign activities.
The United States has and continues to enforce multiple authorities that target a range of
Iranian malign activity outside of Iran’s nuclear program, including Iran’s support for
terrorism, ballistic missile program, human rights abuses, and destabilizing activity in the
region. Treasury will continue to target aggressively anyone who engages in such
sanctionable activity, regardless of whether the individual or entity was removed from the
SDN List on Implementation Day. [05-08-2018]
4. LICENSING
4.1. Will OFAC continue to consider license applications under the Statement of
Licensing Policy for Activities Related to the Export or Re-export to Iran of
Commercial Passenger Aircraft and Related Parts and Services (JCPOA SLP)?
No. Following the issuance of the May 8, 2018 NSPM, OFAC rescinded the JCPOA
SLP and will no longer evaluate applications under the JCPOA SLP. OFAC will still
consider applications, however, under the safety of flight statement of licensing policy
found in 31 C.F.R. § 560.528. [05-08-2018]
4.2. Does OFAC anticipate revoking specific licenses issued under the JCPOA
SLP?
Yes. To the extent they have not yet expired, OFAC expects to revoke the specific
licenses issued pursuant to the JCPOA SLP and issue authorizations to provide for a
wind-down period that will end on August 6, 2018. License applications that were
submitted to OFAC pursuant to the JCPOA SLP but for which no license has been issued
will be returned without action. Applicants may resubmit their applications for
consideration under the safety of flight statement of licensing policy found in 31 C.F.R.
§ 560.528. [05-08-2018]
4.3. Is General License I (GL I) still in effect?
Following the issuance of the May 8, 2018 NSPM, OFAC removed from its website, and
will no longer evaluate applications under, the JCPOA SLP. At that time, OFAC
announced its intention to revoke, as soon as is administratively feasible, GL I, which
authorized U.S. persons to enter into, and to engage in transactions that are ordinarily
incident to the negotiation of and entry into, contingent contracts for activities eligible for
authorization under the JCPOA SLP. OFAC also announced its intention to publish in
the Federal Register a revised authorization for the wind-down of activities authorized
pursuant to GL I. The wind-down of those activities authorized pursuant to GL I must be
completed by August 6, 2018.
OFAC has revoked GL I and issued a wind-down general license that authorizes, through
August 6, 2018, the wind down of activities involving Iran that were previously
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
11
authorized pursuant to GL I. This wind-down general license will appear at 31 C.F.R.
§ 560.536. [05-08-2018; updated on 06-27-2018]
4.4. Is General License H (GL H) still in effect during the wind-down period?
Following the issuance of the May 8, 2018 NSPM, OFAC announced its intention to
revoke GL H, which authorized U.S.-owned or -controlled foreign entities to engage in
certain activities involving Iran, as soon as is administratively feasible. OFAC also
announced its intention to issue a revised authorization for the wind down of activities
involving Iran authorized pursuant to GL H. The wind-down of those activities
authorized pursuant to GL H must be completed by November 4, 2018. Any activities by
U.S.-owned or -controlled foreign entities that continue after the wind-down period
concludes on November 4, 2018, in violation of the ITSR may be subject to enforcement
actions by OFAC. In considering what potential enforcement or sanctions actions to take
with respect to activities engaged in after November 4, 2018, OFAC will take into
account the efforts to wind down activities involving Iran prior to that date.
OFAC has revoked GL H and issued a wind-down general license that authorizes,
through November 4, 2018, the wind down of activities involving Iran that were
previously authorized pursuant to GL H. This wind-down general license will appear at
31 C.F.R. § 560.537. [05-08-2018; updated on 06-27-2018]
4.5. Can I continue to import Iranian-origin carpets and foodstuffs after May 8,
2018?
Following the issuance of the May 8, 2018 NSPM, OFAC announced its intention to
amend the general licenses at 31 C.F.R. §§ 560.534 (authorizing the importation into the
United States of, and dealings in, certain Iranian-origin carpets and foodstuffs) and
560.535 (authorizing certain related letters of credit and brokering services) as soon as is
administratively feasible in order to narrow the scope of those general licenses to
authorize the wind-down of activities by August 6, 2018, that were undertaken consistent
with the sanctions relief provided for in the JCPOA. Any activities by U.S. persons or
U.S.-owned or -controlled foreign entities that continue after the wind-down period
concludes on August 6, 2018, in violation of the ITSR may be subject to enforcement
actions by OFAC. In considering what potential enforcement or sanctions actions to take
with respect to activities engaged in after August 6, 2018, OFAC will take into account
the efforts to wind-down activities involving Iran prior to that date.
OFAC has amended the ITSR to narrow the scope of the general licenses at 31 C.F.R.
§§ 560.534 and 560.535 to authorize the wind down, through August 6, 2018, of
activities that were previously authorized under those general licenses. [05-08-2018;
updated on 06-27-2018]
Annex 144
Issued on May 8, 2018
Last Updated on August 6, 2018
12
5. OTHER
5.1. Will the United States resume efforts to reduce Iran’s crude oil sales?
Yes. The sanctions lifted under section 1245(d) of the NDAA will be re-imposed
following a 180-day wind-down period, and the United States will again pursue efforts to
reduce Iran’s sales of crude oil under the NDAA during and following that period. For
more information about NDAA sanctions, see Topic NDAA (Section 1245 of the
National Defense Authorization Act for Fiscal Year 2012). [05-08-2018]
5.2. How and when will significant reduction exceptions be determined?
The State Department will evaluate and make determinations with respect to significant
reduction exceptions provided for in section 1245(d)(4)(D) of the NDAA at the end of the
180-day wind-down period. Countries seeking such exceptions are advised to reduce
their volume of crude oil purchases from Iran during this wind-down period. Consistent
with past practice, the Secretary of State, in consultation with the Secretary of the
Treasury, the Secretary of Energy, and the Director of National Intelligence, would make
such determinations following a process of rigorous due diligence. For the initial set of
such determinations, the State Department intends to consider relevant evidence in
assessing each country’s efforts to reduce the volume of crude oil imported from Iran
during the 180-day wind-down period, including the quantity and percentage of the
reduction in purchases of Iranian crude oil, the termination of contracts for future
delivery of Iranian crude oil, and other actions that demonstrate a commitment to
decrease substantially such purchases. The State Department expects to engage in
consultations with countries currently purchasing Iranian crude oil during the 180-day
wind-down period. [05-08-2018]
Annex 144
8/5/2019 May 2018 Guidance on Reimposing Certain Sanctions with Respect to Iran
https://www.treasury.gov/resource-center/sanctions/Programs/Pages/05201… 1/2
U.S. DEPARTMENT OF THE TREASURY
Resource Center
May 2018 Guidance on Reimposing Certain Sanctions with Respect to Iran
11/5/2018
On May 8, 2018, the President announced his decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA) and to begin reimposing
the U.S. nuclear-related sanctions that were lifted to effectuate the JCPOA sanctions relief, following a wind-down period. In conjunction with this
announcement, the President issued National Security Presidential Memorandum-11 directing the U.S. Department of the Treasury and other Departments and Agencies
to take the actions necessary to implement his decision.
Consistent with the President’s guidance, Departments and Agencies implemented 90-day and 180-day wind-down periods for activities involving Iran that were
consistent with the U.S. sanctions relief specified in the JCPOA. To effectuate the wind-down periods, the State Department has issued the necessary statutory
sanctions waivers for the duration of the relevant wind-down periods. In addition, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has revoked,
or amended, as appropriate, general and specific licenses issued in connection with the JCPOA. OFAC also issued new authorizations to allow the wind down of
transactions and activities that were authorized pursuant to the revoked or amended general and specific licenses.
August 6, 2018, marks the final day of the 90-day wind-down period. The President has issued Executive Order 13846 (E.O.) of August 6, 2018, “Reimposing Certain
Sanctions With Respect to Iran” , which reimposes relevant provisions of five Iran sanctions E.O.s that were revoked or amended by E.O. 13716 of January 16,
2016. Executive Order 13846 is effective at 12:01 a.m. eastern daylight time (EDT) on August 7, 2018, at which time the sanctions subject to the 90-day wind-down
period will come into effect pursuant to Executive Order 13846 and, as appropriate, relevant statutory provisions that will no longer be within the scope of the waiver
actions taken by the Secretary of State.
In addition, certain wind-down general licenses (GLs) previously issued by OFAC expire at 11:59 p.m. EDT on August 6, 2018. For detailed information regarding which
GLs expire on August 6 and which sanctions are reimposed on August 7, see FAQ 1.2 of the Frequently Asked Questions Regarding the Re-Imposition of Sanctions
Pursuant to the May 8, 2018 National Security Presidential Memorandum Relating to the Join Comprehensive Plan of Action (JCPOA) .
The 180-day wind-down period ends at 11:59 p.m. eastern standard time (EST) on November 4, 2018, and the remaining sanctions that had been lifted or waived
pursuant to the JCPOA come back into full effect on November 5, 2018. For information about which sanctions will be reimposed on November 5, 2018, see FAQ 1.3 of
the Frequently Asked Questions Regarding the Re-Imposition of Sanctions Pursuant to the May 8, 2018 National Security Presidential Memorandum Relating to the
JCPOA . OFAC will publish additional guidance with respect to the end of the 180-day wind-down period no later than November 4, 2018.
OFAC has posted to its website updated additional frequently asked questions (FAQs) that provide guidance on the sanctions that are to be reimposed and the
relevant wind-down periods. In addition, OFAC has posted to its website FAQs relating to E.O 13846.
The U.S. government will continue to make aggressive use of its authorities to target Iran’s malign behavior.
Annex 146
8/5/2019 May 2018 Guidance on Reimposing Certain Sanctions with Respect to Iran
https://www.treasury.gov/resource-center/sanctions/Programs/Pages/05201… 2/2
Annex 146
Annex 149
Annex 149
Annex 149
Annex 149
Annex 149
Please note that on May 8, 2018, the President announced his decision to cease
the United States’ participation in the Joint Comprehensive Plan of Action
(JCPOA), and to begin re-imposing the U.S. nuclear-related sanctions that
were lifted to effectuate the JCPOA sanctions relief, following a wind-down
period. This document remains available on OFAC’s website only to assist
persons in determining which activities were consistent with the JCPOA
sanctions lifting, as in effect from January 16, 2016 through May 8, 2018.
Please note that the Departments of State and of the Treasury have issued
additional guidance regarding activities that may be undertaken during the
wind-down periods. To the extent there are discrepancies between this
document and guidance issued by the Department of State or the Department
of the Treasury on or after May 8, 2018, the later-issued guidance should be
treated as governing.
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
2
This document is explanatory only and does not have the force of law. Please see particularly
the legally binding provisions cited below governing the sanctions. This document does not
supplement or modify the statutory authorities, Executive orders, or regulations.
Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions
Under the Joint Comprehensive Plan of Action (JCPOA) on Implementation Day1
A. GENERAL QUESTIONS
A. 1. What is Implementation Day? When does the lifting of sanctions under the JCPOA
go into effect?
Implementation Day, which is January 16, 2016, marks the day on which the
International Atomic Energy Agency (IAEA) verified that Iran implemented its nuclearrelated
commitments described in sections 15.1-15.11 of Annex V of the JCPOA.
Simultaneous with the IAEA verification, the European Union (EU) and United States
took the actions necessary to lift sanctions as set out in sections 16 and 17, respectively,
of Annex V of the JCPOA. Following confirmation by the Secretary of State that the
IAEA verified that Iran met its commitments, the Department of the Treasury’s Office of
Foreign Assets Control (OFAC) updated its website to notify the public that the U.S.
sanctions commitments described in section 17 of Annex V of the JCPOA have been
implemented. [01-16-2016]
A. 2. What sanctions were lifted on Implementation Day? What activities involving
Iran are covered by the lifting of sanctions on Implementation Day?
On Implementation Day, the United States lifted the nuclear-related “secondary
sanctions” described in sections 4.1-4.7 of Annex II and 17.1-17.2 of Annex V of the
JCPOA and detailed below. Secondary sanctions generally are directed toward non-U.S.
persons2 for specified conduct involving Iran that occurs entirely outside of U.S.
jurisdiction.
1 For additional information regarding the subjects covered in these Frequently Asked Questions (FAQs), please see
the Guidance Relating to the Lifting of Certain U.S. Sanctions Pursuant to the Joint Comprehensive Place of Action
on Implementation Day (Guidance Document) issued by the U.S. Department of the Treasury and the U.S.
Department of State.
2 For the purpose of these FAQs, the term “non-U.S. person” means any individual or entity excluding any United
States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
3
Specifically, on Implementation Day, the United States lifted the following secondary
sanctions:
Financial and banking-related sanctions (see sections 4.1 of Annex II and 17.1 of
Annex V of the JCPOA and section C of these FAQs);
Sanctions on the provision of underwriting services, insurance, or re-insurance in
connection with activities that are consistent with the JCPOA (see sections 4.2 of
Annex II and 17.1 of Annex V of the JCPOA and section D of these FAQs);
Sanctions on Iran’s energy and petrochemical sectors (see sections 4.3 of Annex
II and 17.1 of Annex V of the JCPOA and section B of these FAQs);
Sanctions on transactions with Iran’s shipping and shipbuilding sectors and port
operators (see sections 4.4 of Annex II and 17.1 of Annex V of the JCPOA and
section E of these FAQs);
Sanctions on Iran’s trade in gold and other precious metals (see sections 4.5 of
Annex II and 17.1 of Annex V of the JCPOA and section F of these FAQs);
Sanctions on trade with Iran in graphite, raw or semi-finished metals such as
aluminum and steel, coal, and software for integrating industrial processes, in
connection with activities that are consistent with the JCPOA (see sections 4.6 of
Annex II and 17.2 of Annex V of the JCPOA and section G of these FAQs);
Sanctions on the sale, supply, or transfer of goods and services used in connection
with Iran’s automotive sector (see sections 4.7 of Annex II and 17.1 of Annex V
of the JCPOA and section H of these FAQs); and
within the United States (including foreign branches), or any person in the United States. However, an entity that is
owned or controlled by a United States person and established or maintained outside the United States (a “U.S.-
owned or -controlled foreign entity”) is eligible to participate in transactions or activities subject to the sanctions
lifting under the JCPOA only to the extent the U.S.-owned or -controlled foreign entity is authorized by OFAC to
engage in such transactions or activities, including pursuant to General License H (see section K of these FAQs).
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
4
Sanctions on associated services for each of the categories above (see sections
4.1-4.7 of Annex II and 17.1-17.2 of Annex V of the JCPOA) (see FAQ A.7 for a
discussion of “associated services”).
In addition to the lifting of the nuclear-related secondary sanctions set out above, on
Implementation Day, the United States removed over 400 individuals and entities from
OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), the
Foreign Sanctions Evaders List (FSE List), and/or the Non-SDN Iran Sanctions Act List
(NS-ISA List), as appropriate, pursuant to its commitment under sections 4.8.1 of Annex
II and 17.3 of Annex V of the JCPOA. The names of those individuals and entities are
set out in Attachment 3 to Annex II of the JCPOA. Beginning on Implementation Day,
non-U.S. persons will no longer be subject to sanctions for conducting transactions with
any of the more than 400 individuals and entities set out in Attachment 3 to Annex II of
the JCPOA, including the Central Bank of Iran (CBI) and the specified Iranian financial
institutions, provided these transactions do not involve persons on the SDN List after
Implementation Day or conduct described in FAQ A.3.ii-iii. That said, secondary
sanctions continue to apply to non-U.S. persons for conducting transactions with any of
the more than 200 Iranian or Iran-related individuals and entities who remain or are
placed on the SDN List, notwithstanding the lifting of secondary sanctions on categories
and sectors as set out above (see FAQ A.6).
Pursuant to its commitments under sections 4 of Annex II and 17.4 of Annex 5, the
United States terminated Executive Orders 13574, 13590, 13622, and 13645, and sections
5-7 and 15 of Executive Order 13628 (see FAQs A.8 and A.9).
Pursuant to sections 5 of Annex II and 17.5 of Annex V of the JCPOA, the United States
has committed to license three categories of activity that would otherwise be prohibited
under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR),
provided that the transactions do not involve individuals and entities on the SDN List and
are otherwise consistent with the JCPOA and applicable U.S. law. Accordingly, on
Implementation Day, OFAC issued:
A Statement of Licensing Policy allowing for the case-by-case licensing of
individuals and entities seeking to export, reexport, sell, lease, or transfer to Iran
commercial passenger aircraft, and related parts and services, for exclusively
commercial passenger aviation (see section J of these FAQs);
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
5
A general license authorizing U.S.-owned or -controlled foreign entities to engage
in certain activities involving Iran (see section K of these FAQs); and
A general license, which is effective upon publication in the Federal Register,
authorizing the importation into the United States of Iranian-origin carpets and
foodstuffs, including pistachios and caviar (see section L of these FAQs).
The U.S. commitments to lift secondary sanctions described in these FAQs do not apply
to transactions or activities involving individuals and entities who remain or are placed
on OFAC’s SDN List after Implementation Day and are without prejudice to any other
U.S. sanctions that may apply under legal provisions other than those cited in section 4 of
Annex II of the JCPOA.3 [01-16-2016]
A. 3. Broadly, what U.S. sanctions against Iran remain in place after Implementation
Day? What activities involving Iran trigger sanctions after Implementation Day?
A number of U.S. sanctions authorities with respect to Iran remain in place after
Implementation Day, including those set out below.
i. Primary U.S. Sanctions. The U.S. domestic trade embargo on Iran remains in
place. Even after Implementation Day, with limited exceptions, U.S. persons4 –
including U.S. companies – continue to be broadly prohibited from engaging in
transactions or dealings with Iran or its government. In addition, the Government
of Iran and Iranian financial institutions remain persons whose property and
interests in property are blocked under Executive Order 13599 and section
560.211 of the ITSR, and U.S. persons continue to be broadly prohibited from
engaging in transactions or dealings with the Government of Iran and Iranian
financial institutions, with the exception of transactions that are exempt from
regulation or authorized by OFAC. Unless an exemption or express OFAC
authorization applies, U.S. persons continue to have an obligation to block the
3 For example, a transaction involving Iran that would be sanctionable under an authority that is not lifted pursuant
to the JCPOA (e.g., a U.S. sanctions authority relating to Yemen or Syria) remains sanctionable under that other
authority after Implementation Day.
4 For the purpose of primary U.S. sanctions administered by OFAC and these FAQs, the term “U.S. person” means
any United States citizen, permanent resident alien, entity organized under the laws of the United States or any
jurisdiction within the United States (including foreign branches), or any person in the United States. See section
560.314 of the ITSR. While a U.S. branch of a foreign financial institution would be considered a U.S. person for
the purposes of the ITSR, the foreign financial institution located outside the United States would not.
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
6
property and interests in property of all individuals and entities that meet the
definition of the Government of Iran or an Iranian financial institution, regardless
of whether or not the individual or entity has been identified by OFAC on the
E.O. 13599 List (see FAQ I.2). In addition, non-U.S. persons continue to be
prohibited from knowingly5 engaging in conduct that seeks to evade U.S.
restrictions on transactions or dealings with Iran or that causes the export of goods
or services from the United States to Iran.
ii. Designation authorities. In addition, after Implementation Day, the United States
retains a number of authorities to counter Iran’s other activities, including the
following authorities which are also listed in section VII.B of the Guidance
Document:
o Support for terrorism: Executive Order 13224 (blocking property and
prohibiting transactions with persons who commit, threaten to commit, or
support terrorism);
o Iran’s human rights abuses:
Executive Orders 13553 and 13628 (implementing sections 105,
105A, and 105B of CISADA (related to persons who are
responsible for or complicit in human rights abuses committed
against the citizens of Iran; transfers of goods or technologies to
Iran that are likely to be used to commit serious human rights
abuses against the people of Iran; and persons who engage in
censorship or similar activities with respect to Iran)); and
Executive Order 13606 (relating to the provision of information
technology used to further serious human rights abuses);
o Proliferation of WMD and their means of delivery, including ballistic
missiles: Executive Orders 12938 and 13382;
5 For the purpose of these FAQs, with respect to conduct, a circumstance, or a result, the term “knowingly” means
that a person has actual knowledge, or should have known, of the conduct, the circumstance, or the result (see FAQ
289).
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
7
o Support for persons involved in human rights abuses in Syria or for the
Government of Syria: Executive Orders 13572 and 13582; and
o Support for persons threatening the peace, security, or stability of Yemen:
Executive Order 13611.
These authorities generally provide the ability to impose blocking sanctions on
individuals and entities that meet specified criteria, including for providing
material support to persons engaged in the activities targeted by the authority.
iii. Secondary Sanctions targeting dealings by non-U.S. persons with Iran-related
persons remaining on the SDN List after Implementation Day or involving trade
in certain materials involving Iran. After Implementation Day, secondary
sanctions continue to attach to significant6 transactions with: (1) Iranian persons
that are on the SDN List; (2) the Islamic Revolutionary Guard Corps (IRGC) and
its designated agents or affiliates; and (3) any other person on the SDN List
designated under Executive Order 13224 or Executive Order 13382 in connection
with Iran’s proliferation of weapons of mass destruction (WMD) or their means of
delivery or Iran’s support for international terrorism (see FAQ A.6). In addition,
sanctions targeting certain activities related to trade in materials described in
section 1245(d) of the Iran Freedom and Counter-Proliferation Act of 2012
(IFCA) that are outside the scope of the JCPOA and related waivers remain in
place.
See section VII of the Guidance Document for additional information regarding U.S.
legal authorities directed toward, or that have been used to address, U.S. concerns with
respect to Iran, which are outside the scope of the JCPOA and remain in place following
Implementation Day. [01-16-2016]
A. 4. How did the United States lift sanctions on Implementation Day?
On Implementation Day, the United States lifted the secondary sanctions described in
sections 4.1-4.8 of Annex II and 17.1-17.4 of Annex V of the JCPOA by (1) issuing
waivers of certain statutory sanctions provisions, (2) committing to refrain from
exercising certain discretionary sanctions authorities, (3) removing certain individuals
6 For the purpose of these FAQs, OFAC will rely on the interpretation set out in 561.404 of the IFSR in determining
whether transactions, financial transactions, or financial services are significant (see FAQ 289).
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
8
and entities from OFAC’s sanctions lists, and (4) revoking certain Executive orders and
specified sections of an Executive order.
Waivers and Non-Exercise of Discretionary Authorities. On October 18, 2015,
or “Adoption Day” under the JCPOA, the Department of State issued contingent
waivers of certain statutory sanctions provisions. These waivers came into effect
on Implementation Day upon confirmation by the Secretary of State that Iran
implemented the nuclear-related measures specified in sections 15.1-15.11 of
Annex V of the JCPOA, as verified by the IAEA. Sections II and VI of the
Guidance Document provide details on the specific provisions waived on
Implementation Day and certain discretionary sanctions authorities the United
States has committed not to exercise.
Removal of Sanctions Listings. On Implementation Day, the individuals and
entities set out in Attachment 3 to Annex II of the JCPOA were removed from the
SDN List, FSE List, and/or NS-ISA List, as appropriate (see FAQ I.1).
Termination of Executive Orders. On Implementation Day, the President issued
an Executive order revoking Executive Orders 13574, 13590, 13622, and 13645,
and sections 5-7 and 15 of Executive Order 13628, as provided for in section 17.4
of Annex V of the JCPOA (see FAQs A.8 and A.9).
In addition, on Implementation Day, the United States issued a Statement of Licensing
Policy and two general licenses to implement its commitments under sections 5 of Annex
II and 17.5 of Annex V of the JCPOA (see sections J, K, and L of these FAQs). [01-16-
2016]
A. 5. Are U.S. persons able to engage in any of the transactions with Iran outlined in the
JCPOA?
The United States committed under the JCPOA to license U.S. persons to engage in
certain transactions related to three categories of activity set out in section 5 of Annex II
of the JCPOA (see sections J, K, and L of these FAQs). However, post-Implementation
Day, U.S. persons continue to be generally prohibited from engaging in transactions or
dealings involving Iran, including the Government of Iran and Iranian financial
institutions, with the exception of specific activities that are exempt from regulation or
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
9
authorized by OFAC, including the three categories of activity that the United States
committed to licensing. Following Implementation Day, U.S. persons continue to be
authorized to undertake a range of activities involving Iran pursuant to general licenses
issued by OFAC, including for example the longstanding authorization for exports to Iran
of agricultural commodities (including food), medicine, and medical supplies. [01-16-
2016]
A. 6. Post-Implementation Day, are transactions with Iran-related persons who
remain on the SDN List sanctionable? How do I know if secondary sanctions
attach to a transaction with a person on the SDN List?
Yes. While over 400 individuals and entities were removed from the SDN list on
Implementation Day, secondary sanctions continue to apply to non-U.S. persons who
knowingly facilitate significant financial transactions with or provide material or certain
other support to those Iranian or Iran-related persons that remain or are placed on the
SDN List.
In particular, after Implementation Day, secondary sanctions continue to attach to such
activities with: (1) Iranian persons that remain or are placed on the SDN List; (2) the
IRGC and its designated agents or affiliates; and (3) any other person on the SDN List
designated under Executive Order 13224 or Executive Order 13382 in connection with
Iran’s proliferation of WMD or their means of delivery or Iran’s support for international
terrorism.
To assist the public, SDN List entries for these persons contain the phrase “Subject to
Secondary Sanctions” in the “Additional Sanctions Information” field. In addition, SDN
List entries for persons subject to secondary sanctions pursuant to section 104(c)(2)(E) of
the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
(CISADA) include special identifying tags: the IRGC and its designated agents or
affiliates are identified with the tag “[IRGC]” and SDNs designated pursuant to
Executive Order 13224 or Executive Order 13382 in connection with, respectively, Iran’s
proliferation of WMD or their means of delivery or Iran’s support for international
terrorism are identified with the tag “[IFSR].”
For a list of additional activities that can subject a foreign financial institution to
secondary sanctions pursuant to CISADA, see FAQ 149.
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
10
In addition, U.S. persons continue to be generally prohibited from dealing with persons
on the SDN List. The SDN List has the potential to change and persons should continue
to monitor the SDN List for the most up-to-date information. [01-16-2016]
A. 7. Is the provision of associated services that are ordinarily incident to the underlying
activities for which sanctions have been lifted pursuant to the JCPOA allowed?
What does the term “associated services” mean when used in Annex II of the
JCPOA?
Yes. Beginning on Implementation Day, non-U.S. persons may provide associated
services that are ordinarily incident to those activities for which sanctions have been
lifted as described in sections 4.1-4.7 of Annex II and 17.1-17.2 of Annex V of the
JCPOA, provided such services are consistent with the JCPOA and do not involve
persons on the SDN List or other activities that would be sanctionable under U.S. law.
As a general matter, U.S. persons are prohibited from providing associated services in
connection with activities involving Iran; however, they may be authorized by OFAC to
provide such services in connection with activities authorized pursuant to a specific
license, such as for exports of commercial passenger aircraft and related parts and
services covered by the commitment in sections 5.1.1 of Annex II and 17.5 of Annex V
of the JCPOA (see section J of these FAQs), or under a general license, such as that for
the importation of Iranian-origin carpets and foodstuffs into the United States pursuant to
the commitment in sections 5.1.3 of Annex II and 17.5 of Annex V of the JCPOA (see
section L of these FAQs). For purposes of those activities for which sanctions have been
lifted as described in sections 4.1-4.7 of Annex II and 17.1-17.2 of Annex V of the
JCPOA, the term “associated services” means any service – including technical
assistance, training, insurance, re-insurance, brokering, transportation, or financial service
– necessary and ordinarily incident to the underlying activity for which sanctions have
been lifted pursuant to the JCPOA. [01-16-2016]
A. 8. Did the Executive order issued on Implementation Day terminate any sanctions?
Yes. As provided for in sections 4 of Annex II and 17.4 of Annex V of the JCPOA, the
Executive order published on Implementation Day revoked Executive Orders 13574,
13590, 13622, and 13645, and sections 5-7 and 15 of Executive Order 13628. However,
sanctions authorities contained in the remaining sections of Executive Order 13628
remain in effect.
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
11
The Executive order that was published on Implementation Day has no effect on the
national emergency declared in 1995 with respect to Iran, which remains in place, or on
any Executive order issued in furtherance of that national emergency other than
Executive Orders 13574, 13590, 13622, 13628, and 13645. [01-16-2016]
A. 9. Did the Executive order issued on Implementation Day impose new sanctions with
respect to Iran?
No. The new Executive order did not impose any new sanctions with respect to Iran.
However, the Executive order includes certain technical provisions that relate to the
implementation of statutory authorities that are outside the scope of U.S. commitments
with respect to sanctions described in sections 4.1-4.8 and 5 of Annex II and sections
17.1-17.3 and 17.5 of Annex V of the JCPOA. Specifically, these provisions apply to the
extent sanctions are imposed pursuant to sections 1244(c)(1), 1244(d)(1)(A), 1245(a)(1),
and 1246(a) of IFCA with respect to transactions or activities that are outside the scope of
the U.S. commitments with respect to sanctions under the JCPOA. [01-16-2016]
A. 10. What is Transition Day? What will happen on Transition Day?
Transition Day will occur eight years from Adoption Day, which occurred on October 18,
2015, or upon the date the IAEA has reached the Broader Conclusion that all nuclear
material in Iran is used for peaceful activities, whichever is earlier.
On Transition Day, the United States will remove individuals and entities set out in
Attachment 4 to Annex II of the JCPOA from the SDN List and/or the FSE List, as set
out in section 21.3 of Annex V of the JCPOA.7
In addition, the United States will seek such legislative action as may be appropriate to
terminate, or modify to effectuate the termination of, the statutory sanctions set forth in
sections 4.1-4.5, 4.7, and 4.9 of Annex II of the JCPOA and the statutory sanctions
described in section 4.6 of Annex II, in connection with activities consistent with the
JCPOA, as set out in sections 21.1-21.2 of Annex V of the JCPOA. OFAC anticipates
issuing further guidance on Transition Day measures prior to Transition Day. [01-16-
2016]
7 Pursuant to relevant statutes and Executive orders, the U.S. government retains the ability to remove persons from
the relevant sanctions lists prior to Transition Day if the circumstances warrant.
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
12
A. 11. What happens to the sanctions suspended under the JPOA?
The sanctions that were temporarily suspended under the Joint Plan of Action of
November 24, 2013, as extended (JPOA), are a subset of those sanctions that were lifted
on Implementation Day pursuant to the JCPOA. Consequently, upon Implementation
Day, the JPOA ceased to be in effect and the relevant sanctions lifting was provided as
part of the JCPOA. [01-16-2016]
B. ENERGY AND PETROCHEMICAL SECTORS
B. 1. The JCPOA provides that, on Implementation Day, the United States will cease
efforts to reduce Iran’s crude oil sales, including limitations on the quantities of
Iranian crude sold, the jurisdictions that can purchase Iranian crude oil, and how
Iranian oil revenues can be used. Are non-U.S. persons able to purchase Iranian oil
beginning on Implementation Day?
Yes. As a result of the U.S. commitments specified in sections 4.3 of Annex II and 17.1
of Annex V of the JCPOA, beginning on Implementation Day, the United States is no
longer pursuing efforts to reduce Iran’s sales of crude oil under the National Defense
Authorization Act for Fiscal Year 2012 (NDAA) (including limitations on the quantity of
crude sold and the jurisdictions that can purchase Iranian crude oil). The restriction on
use of proceeds of sales of Iranian petroleum and petroleum products for bilateral trade
with Iran, which previously applied to the 20 jurisdictions with a so-called “significant
reduction exception” under the NDAA, no longer apply. In addition, the restrictions on
Iranian oil revenues held abroad have been lifted.
Consequently, beginning on Implementation Day, secondary sanctions do not apply to
non-U.S. persons that purchase, acquire, sell, transport, or market Iranian crude oil,
provided that the transactions do not involve persons on the SDN List or conduct
described in FAQ A.3.ii-iii.
U.S. persons continue to be generally prohibited under the ITSR from involvement in the
activity described above. In addition, transactions related to the above-mentioned
activity are prohibited from transiting the U.S. financial system. [01-16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
13
B. 2. Can non-U.S. persons invest in Iran’s oil, gas, and petrochemical sectors beginning
on Implementation Day?
Yes. As a result of the U.S. commitments specified in sections 4.3 of Annex II and 17.1
of Annex V of the JCPOA, beginning on Implementation Day, the United States lifted
sanctions on investments by non-U.S. persons in the oil, gas, or petrochemical sectors of
Iran. As a result, non-U.S. persons are no longer subject to sanctions for investing in
Iran’s oil, gas, or petrochemical sectors (including through participation in joint
ventures), provided that transactions do not involve persons on the SDN List or conduct
described in FAQ A.3.ii-iii. [01-16-2016]
B. 3. Can non-U.S. persons provide goods and services in connection with Iran’s energy
sector beginning on Implementation Day?
Yes. As a result of the U.S. commitments specified in sections 4.3 of Annex II and 17.1
of Annex V of the JCPOA, beginning on Implementation Day, it is no longer
sanctionable for non-U.S. persons to provide goods, services (including financial
services), or technology used in connection with Iran’s energy sector, the development of
Iran’s petroleum resources, including the domestic production of refined petroleum
products and petrochemical products, or associated services, provided that transactions do
not involve persons on the SDN List or conduct described in FAQ A.3.ii-iii. [01-16-
2016]
B. 4. Beginning on Implementation Day, can non-U.S. persons purchase, acquire, sell,
transport, or market petroleum, petrochemical products, and natural gas from
Iran?
Yes. On Implementation Day, the United States lifted secondary sanctions on the
purchase, acquisition, sale, transport, or marketing of petroleum, petroleum products
(including refined petroleum products), petrochemical products, and natural gas
(including liquefied natural gas) from Iran, and the provision of associated services. As a
result, beginning on Implementation Day, non-U.S. persons are no longer subject to
sanctions for engaging in such activities, provided that transactions do not involve
persons on the SDN List or conduct described in FAQ A.3.ii-iii. [01-16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
14
B. 5. Beginning on Implementation Day, can non-U.S. persons export, sell, or provide
refined petroleum products and petrochemical products to Iran?
Yes. On Implementation Day, the United States lifted secondary sanctions on the export,
sale, or provision of refined petroleum products and petrochemical products to Iran. As a
result, beginning on Implementation Day, non-U.S. persons are no longer subject to
sanctions for engaging in these activities, provided that transactions do not involve
persons on the SDN List or conduct described in FAQ A.3.ii-iii. [01-16-2016]
B. 6. Beginning on Implementation Day, can U.S. persons export, sell, or provide goods,
services, or technology to Iran’s energy sector?
No. Under section 560.204 of the ITSR, U.S. persons continue to be broadly prohibited
from exporting any goods, services, or technology directly or indirectly to Iran, with the
exception of transactions that are exempt from regulation or authorized by OFAC (see
FAQ M.9). [01-16-2016]
B. 7. Beginning on Implementation Day, are non-U.S. persons able to engage in
transactions with Iran’s energy sector, including the National Iranian Oil Company
(NIOC), the Naftiran Intertrade Company (NICO), and the National Iranian
Tanker Company (NITC)?
Yes. On Implementation Day, the United States lifted secondary sanctions on Iran’s
energy sector. As part of its efforts to give effect to this relief, the United States resolved
a number of past designations and determinations, including the Department of the
Treasury’s determination with respect to NIOC under section 312 of the TRA. In
particular, the Department of the Treasury determined that NIOC is no longer an agent or
affiliate of the IRGC. Beginning on Implementation Day, non-U.S. persons are no longer
subject to sanctions for engaging in activities with Iran’s energy sector, including
transactions with NIOC, NITC, and NICO, and the provision of associated services,
provided that transactions do not involve persons on the SDN List or conduct described
in FAQ A.3.ii-iii. [01-16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
15
B. 8. Beginning on Implementation Day is it permissible to make payments for Iranian
oil through the U.S. financial system?
No. The JCPOA provides that, on Implementation Day, the United States ceased efforts
to reduce Iran’s crude oil sales and lifted secondary sanctions on investment in Iran’s oil,
gas, and petrochemical sectors, as well as on the export, sale or provision of refined
petroleum. This lifting of sanctions pertains solely to non-U.S. persons, and U.S. persons
continue to be prohibited from engaging in activities related to Iran’s energy sector.
Similarly, as a general matter, U.S. financial institutions continue to be prohibited from
processing payments related to Iranian oil. [01-16-2016]
C. FINANCIAL AND BANKING MEASURES
C. 1. Which financial and banking sanctions are relieved under the JCPOA?
Pursuant to U.S. commitments in sections 4.1 of Annex II and 17.1 of Annex V of the
JCPOA, beginning on Implementation Day, secondary sanctions do not apply to non-U.S.
persons who engage in:
Financial and banking transactions with individuals and entities removed from the
SDN List, FSE List, and/or NS-ISA List, as appropriate, on Implementation Day
(including sanctions on the opening and maintenance of correspondent and
payable-through accounts, investments, foreign exchange transactions, and letters
of credit). Individuals and entities that were removed include the CBI and most
other Iranian financial institutions, NIOC, NICO, NITC, and other specified
individuals and entities identified by OFAC as the Government of Iran on the
SDN List. For the full list of individuals and entities that were removed from
SDN List, FSE List, and/or NS-ISA List on Implementation Day, see Attachment
3 to Annex II of the JCPOA;
Transactions and other activity related to the Iranian rial;
Provision of U.S. bank notes to the Government of Iran, including the provision
of material support for such transactions;
The purchase, subscription to, or facilitation of the issuance of Iranian sovereign
debt, including governmental bonds; and
The provision of financial messaging services to the CBI and other Iranian
financial institutions removed from the SDN List on Implementation Day.
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
16
The U.S. commitments also include the lifting of bilateral trade limitations on CBI
revenues held abroad, including limitations on their transfer, as set forth in section
1245(d) of the NDAA. As a result of the lifting of these sanctions, foreign financial
institutions8 are able to conduct transactions with respect to the CBI’s previously
restricted funds abroad unless such transactions involve persons that remain on the SDN
List or conduct described in FAQ A.3.ii-iii.
U.S. persons continue to be generally prohibited under the ITSR from involvement in the
activity described above. In addition, transactions related to the above-mentioned
activity are prohibited from transiting the U.S. financial system. [01-16-2016]
C. 2. What sanctions on the CBI were lifted? What sanctions on the CBI remain?
As a general matter, non-U.S. persons, including foreign financial institutions, can
engage in financial and banking transactions with the CBI beginning on Implementation
Day without exposure to sanctions. U.S. persons, however, continue to be broadly
prohibited from engaging in transactions or dealings with the Government of Iran and
Iranian financial institutions, including the CBI, with the exception of transactions that
are exempt from regulation or authorized by OFAC. In addition, unless an exemption or
express OFAC authorization applies, U.S. persons must, pursuant to Executive Order
13599 and the ITSR, continue to block the property and interests in property of these
persons. [01-16-2016]
8 A foreign financial institution is defined in section 561.308 of the Iranian Financial Sanctions Regulations, 31
C.F.R. part 561 (IFSR), as any foreign entity that is engaged in the business of accepting deposits, making, granting,
transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, commodity
futures or options, or procuring purchasers and sellers thereof, as principal or agent. It includes but is not limited to
depository institutions, banks, savings banks, money service businesses, trust companies, securities brokers and
dealers, commodity futures and options brokers and dealers, forward contract and foreign exchange merchants,
securities and commodities exchanges, clearing corporations, investment companies, employee benefit plans, dealers
in precious metals, stones, or jewels, and holding companies, affiliates, or subsidiaries of any of the foregoing. For
purposes of the lifting of sanctions set out in sections 4.1.1-4.1.7 of Annex II and 17.1 of Annex V of the JCPOA,
the effects of the sanctions lifting described for non-U.S financial institutions extend to the activities outside of U.S.
jurisdiction of international financial institutions, including those identified in 22 U.S.C. § 262r(c)(2).
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
17
C. 3. After Implementation Day, will foreign financial institutions be subject to sanctions
for conducting or facilitating transactions with persons removed from the SDN
List?
No. As set out in the JCPOA, foreign financial institutions are able to conduct or
facilitate financial transactions with persons listed in Attachment 3 to Annex II of the
JCPOA who have been removed from the SDN List, FSE List, and/or NS-ISA List, as
appropriate, provided that such transactions do not involve persons on the SDN List or
conduct described in FAQ A.3.ii-iii. This would include transactions by foreign financial
institutions that have branches in the United States, provided that the branches in the
United States are not directly or indirectly involved in the transactions. In addition, such
transactions may not transit the U.S. financial system. [01-16-2016]
C. 4. Will foreign financial institutions be subject to sanctions for opening or maintaining
correspondent accounts for Iranian financial institutions removed from the SDN
List?
No. As set out in the JCPOA, foreign financial institutions will not be not subject to
secondary sanctions for opening or maintaining correspondent accounts for Iranian
financial institutions listed in Attachment 3 to Annex II of the JCPOA that have been
removed from the SDN List, FSE List, and/or NS-ISA List, as appropriate, provided that
such activity does not include conduct described in FAQ A.3.ii-iii, and provided further
that the foreign financial institution does not conduct or facilitate, and is not otherwise
involved in, specific transactions or banking relationships with Iranian individuals and
entities, including financial institutions, on the SDN List. Any transactions processed to
or through the United States or that involve a U.S. person, directly or indirectly, continue
to be prohibited unless they are exempt from regulation or authorized by OFAC. [01-16-
2016]
C. 5. The JCPOA provides that the United States will lift secondary sanctions related to
the provision of financial messaging services to the CBI and Iranian financial
institutions set out in Attachment 3 to Annex II on Implementation Day. Does this
mean that these Iranian banks can receive specialized financial messaging services
from non-U.S. providers?
Yes. As detailed in section 4.1.6 of Annex II of the JCPOA, the United States will not
impose sanctions on non-U.S. persons that provide specialized financial messaging
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
18
services to, or enable or facilitate direct or indirect access to such services for, the CBI or
Iranian financial institutions, with the exception of entities that remain or are placed on
the SDN List (as of Implementation Day, Iranian financial institutions remaining on the
SDN List are: Ansar Bank, Bank Saderat, Bank Saderat PLC, and Mehr Bank).
U.S. persons – including U.S. financial institutions – continue to be broadly prohibited
from engaging in transactions involving Iran, including the provision of specialized
financial messaging services to, or enabling or facilitating direct or indirect access to such
services for, the CBI or Iranian financial institutions, unless the transactions are exempt
from regulation or authorized by OFAC. In addition, see FAQ C.7 regarding prohibitions
on clearing U.S. dollar transactions involving Iranian persons through the United States.
[01-16-2016]
C. 6. Are U-turn transactions involving the United States allowed after Implementation
Day?
No. After Implementation Day, U.S. persons continue to be prohibited from exporting
goods, services (including financial services), or technology directly or indirectly to Iran.
The so-called “U-turn general license,” which allowed U.S. dollar clearing activities
involving Iran prior to its revocation in November 2008, was not reinstated on
Implementation Day, and U.S. financial institutions continue to be prohibited from
clearing transactions involving Iran, with the exception of transactions that are exempt or
authorized by a general or specific license issued pursuant to the ITSR. [01-16-2016]
C. 7. After Implementation Day, can foreign financial institutions, including foreignincorporated
subsidiaries of U.S. financial institutions, process transactions
denominated in U.S. dollars or maintain U.S. dollar-denominated accounts on
behalf of the Government of Iran or any person subject to the jurisdiction of the
Government of Iran, such as NIOC or the CBI?
Yes. Foreign financial institutions, including foreign-incorporated subsidiaries of U.S.
financial institutions, may process transactions denominated in U.S. dollars or maintain
U.S. dollar-denominated accounts that involve Iran or persons ordinarily resident in Iran,
or in which there is an interest of a person whose property and interests in property are
blocked solely pursuant to Executive Order 13599 and section 560.211 of the ITSR,
including NIOC, the CBI, and other individuals and entities that meet the definition of the
Government of Iran or an Iranian financial institution, provided that such transactions or
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
19
account activities do not involve, directly or indirectly, the United States financial system
or any United States person, and do not involve any person on the SDN List or conduct
described in FAQ A.3.ii-iii. See section K of these FAQs for information on General
License H, which authorizes U.S.-owned or -controlled foreign entities to engage in
certain activities involving Iran.
However, even after Implementation Day, foreign financial institutions, including
foreign-incorporated subsidiaries of U.S. financial institutions, need to continue to ensure
they do not process U.S. dollar-denominated transactions involving Iran through the U.S.
financial system or otherwise involve U.S. financial institutions (including their foreign
branches), given that U.S. persons continue to be prohibited from exporting goods,
services (including financial services), or technology directly or indirectly to Iran, with
the exception of transactions that are exempt or authorized by a general or specific
license issued pursuant to the ITSR. U.S. persons continue to be prohibited from
engaging in any transactions involving Iran, including in currencies other than the U.S.
dollar, with the exception of transactions that are exempt or authorized by OFAC. [01-
16-2016; updated on 10-07-2016]
C. 8. The JCPOA provides that the United States will lift secondary sanctions on the
provision of U.S. bank notes to the Government of Iran on Implementation Day.
What does this entail?
As detailed in section 4.1.3 of Annex II of the JCPOA, beginning on Implementation
Day, the provision of U.S. bank notes to the Government of Iran by non-U.S. persons is
no longer sanctionable, provided that the transaction does not involve any person on the
SDN List or conduct described in FAQ A.3.ii-iii. U.S. persons continue to be prohibited
from directly or indirectly providing U.S. bank notes to the Government of Iran. In
addition, transactions related to the above-mentioned activity continue to be prohibited
from transiting the U.S. financial system. [01-16-2016]
C. 9. What are the due diligence expectations for U.S. financial institutions in
investigating Iran-related transactions?
For purposes of overall sanctions compliance, Treasury expects that U.S. financial
institutions will continue to implement a risk-based compliance program that tailors
internal policies, procedures, and processes to appropriately mitigate their sanctions
exposure.
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
20
For all OFAC sanctions programs – including the Iran sanctions program – a financial
institution should ensure that it has the appropriate procedures in place to identify,
escalate, interdict, and report transactions that are in violation of sanctions regulations.
OFAC continues to provide industry-specific guidance on compliance policies and
procedures on its website, and specific questions relating to Iran-related transactions can
be directed to the OFAC Hotline at 1-800-540-6322 or 202-622-2490. For more
information regarding best practices in complying with the sanctions administered by
OFAC, please see FAQ 116. [01-16-2016]
C. 10. After Implementation Day, are foreign financial institutions subject to sanctions
for processing transactions involving activity for which sanctions have been lifted
under the JCPOA?
No. Beginning on Implementation Day, foreign financial institutions are able to conduct
or facilitate financial transactions in connection with activities for which sanctions have
been lifted on Implementation Day, provided that the transactions do not involve persons
on the SDN List and such activity does not include conduct described in FAQ A.3.ii-iii.
Foreign financial institutions should continue to undertake their customary due diligence
to ensure that they are not facilitating transactions that remain sanctionable. [01-16-
2016]
C. 11. Will foreign financial institutions be exposed to sanctions for transacting with
Iranian financial institutions if those Iranian financial institutions have banking
relationships with Iranian persons on the SDN List?
Beginning on Implementation Day, non-U.S., non-Iranian financial institutions engaging
in transactions with Iranian financial institutions (including the CBI) not appearing on the
SDN List will not be exposed to sanctions as a result of those Iranian financial
institutions engaging in transactions or banking relationships involving Iranian
individuals or entities, including financial institutions, on the SDN List, provided that the
non-U.S., non-Iranian financial institution does not conduct or facilitate, and is not
otherwise involved in, those specific transactions or banking relationships with the
individuals and entities on the SDN List.
For example, a European-headquartered bank that transacts with the CBI or any other
non-designated Iranian financial institution is not subject to secondary sanctions – even if
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
21
the CBI separately has banking relationships with individuals or entities on the SDN List
– provided that the European bank is not involved with any of the CBI’s transactions
involving individuals or entities that remain on the SDN List. [01-16-2016]
C. 12. Would the issuance of credit cards by non-U.S. financial institutions to Iranian
persons not on the SDN List be sanctionable?
No. The issuance of credit cards by non-U.S. financial institutions to non-SDN Iranian
nationals would not be prohibited under OFAC sanctions regulations. Foreign financial
institutions, however, should be aware that the ITSR prohibit the processing of payments
involving Iran by U.S. persons in general, including by or through U.S. financial
institutions, with the exception of transactions that are exempt or authorized by an
applicable general or specific license issued pursuant to the ITSR. Moreover, there may
be secondary sanctions implications to processing credit card transactions if such
transactions involve persons on the SDN List or conduct described in FAQ A.3.ii-iii.
[01-16-2016]
C. 13. The JCPOA provides that the United States will lift secondary sanctions on the
Iranian rial on Implementation Day. Does this mean that foreign financial
institutions are able to buy and sell Iranian rials?
Yes. As detailed in section 4.1.2 of Annex II of the JCPOA, beginning on
Implementation Day, it is no longer sanctionable for foreign financial institutions to
conduct or facilitate any significant transaction related to the purchase or sale of Iranian
rials (or a derivative, swap, future, forward, or other similar contract whose value is based
on the exchange rate of the Iranian rial) or maintain funds or accounts outside of the
territory of Iran denominated in the Iranian rial. [01-16-2016]
C. 14. What U.S. financial and banking measures with respect to Iran remain in place
after Implementation Day?
After Implementation Day, the United States retains the authority to impose
correspondent or payable-through account sanctions on foreign financial institutions that
(1) knowingly facilitate significant financial transactions on behalf of any Iranian person
included on the SDN List, pursuant to section 1247 of IFCA, or (2) facilitate or conduct
significant financial transactions for persons that remain designated in connection with
Iran’s proliferation of WMD or their means of delivery or Iran’s support for international
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
22
terrorism, pursuant to section 104(c)(2)(E)(ii) of CISADA, as amended. Sanctions under
section 104(c)(2)(E)(ii) of CISADA no longer apply to transactions with individuals and
entities removed from the SDN List on Implementation Day (see FAQ I.6).
Further, even after Implementation Day, the prohibitions set forth in the ITSR remain in
place, including the prohibition in section 560.204 of the ITSR on the exportation,
reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S.
person, wherever located, of any goods, technology, or services to Iran or the
Government of Iran, with the exception of transactions that are exempt from regulation or
authorized by OFAC (see FAQ M.9). Consequently, the clearing of U.S. dollar- or other
currency-denominated transactions through the U.S. financial system or involving a U.S.
person remain prohibited, unless the transactions are exempt from regulation or
authorized by OFAC.
Finally, the JCPOA does not impact the November 2011 finding by the Department of
the Treasury’s Financial Crimes Enforcement Network (FinCEN) that Iran is a
Jurisdiction of Primary Money Laundering Concern. Pursuant to section 311 of the USA
PATRIOT Act, the Department of the Treasury has the authority to require U.S. domestic
financial institutions to take “special measures” with respect to jurisdictions, financial
institutions, or international transactions of primary money laundering concern. The
November 2011 finding is based upon multiple factors including activities outside the
scope of the JCPOA and the related sanctions lifting.
See FAQ A.3 and section VII of the Guidance Document for an overview of key U.S.
legal authorities that remain in place after Implementation Day. [01-16-2016]
C. 15. Can U.S. financial institutions transact with, including by opening or maintaining
correspondent accounts for, non-U.S., non-Iranian financial institutions that
maintain correspondent banking relationships with Iranian financial institutions
that are not on the SDN List?
Yes. U.S. financial institutions can transact with, including by opening or maintaining
correspondent accounts for, non-U.S., non-Iranian financial institutions that maintain
correspondent banking relationships or otherwise transact with Iranian financial
institutions that are not on the SDN List. It remains prohibited, however, for non-U.S.
financial institutions to route transactions involving Iran to or through the U.S. financial
system, or involve U.S. persons in such transactions, unless the transactions are exempt
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
23
from regulation or authorized by OFAC. Non-U.S., non-Iranian financial institutions
should have appropriate systems and controls to ensure that they do not route transactions
involving Iran to or through the U.S. financial system unless the transactions are exempt
from regulation or authorized by OFAC. [06-08-2016; updated on 10-07-2016]
C. 16. Can a non-U.S., non-Iranian entity (including a non-U.S., non-Iranian financial
institution) engage in transactions with Iranian persons not on the SDN List even
though one or more U.S. persons serve on that entity’s Board of Directors or as
senior managers (e.g., Chief Executive Officer, Chief Financial Officer, Chief
Operating Officer, Chief Compliance Officer)? Must these U.S. persons be recused
or “walled off” from the entity’s Iran-related business?
The presence of one or more U.S. persons on the Board of Directors or serving as a
senior manager of a non-U.S., non-Iranian entity does not necessarily preclude that entity
from transacting with Iranian persons that are not on the SDN List. Unless authorized by
OFAC, however, U.S. persons must be walled off or “ring-fenced” from Iran-related
business because, with limited exceptions, U.S. persons continue to be broadly prohibited
from engaging in or facilitating transactions or dealings with Iran or its government. The
prohibitions on the exportation or reexportation of services to Iran and facilitation have
been in place for decades, and are consistent with prohibitions applied across a range of
U.S. sanctions programs administered by OFAC.
Non-U.S., non-Iranian entities establishing policies regarding how to wall off the U.S.
persons from the institution’s Iran-related business should consider instituting a blanket
recusal policy (as opposed to case-by-case abstentions, which, depending on the facts and
circumstances, could be considered a prohibited facilitation and/or export of services
under the ITSR) for U.S. person directors, senior managers, and other employees with
respect to Iran-related matters. The institution of a blanket recusal policy requiring that
all U.S. person employees of a non-U.S., non-Iranian entity not be involved in Iranrelated
activities would not be considered prohibited activity under the ITSR. In
instances where national laws prohibit the recusal of a U.S. person executive from the
decision-making processes of his or her non-U.S. employer, including those involving
Iran-related business, the executive or employer should consult with their counsel and/or
approach OFAC for additional guidance. [06-08-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
24
D. INSURANCE MEASURES
D. 1. How does the lifting of sanctions provided under the JCPOA affect the provision of
insurance for transactions involving Iran?
The JCPOA provides that, on Implementation Day, the United States will lift certain
sanctions on the provision of underwriting services, insurance, or reinsurance in
connection with activities that are consistent with the JCPOA, including activities by
non-U.S. persons with individuals and entities set forth in Attachment 3 to Annex II of
the JCPOA. The provision of underwriting services, insurance, or reinsurance by non-
U.S. persons for activity that is consistent with the JCPOA is not sanctionable as of
Implementation Day, provided that the transactions do not involve persons on the SDN
List or conduct described in FAQ A.3.ii-iii. [01-16-2016]
D. 2. Is payment by non-U.S. persons of insurance or reinsurance claims made after
Implementation Day for activity that is consistent with the JCPOA but that took
place and was sanctionable prior to Implementation Day sanctionable?
Beginning on Implementation Day, OFAC will not impose sanctions on a non-U.S.
person for payment of an insurance or reinsurance claim arising from an incident that
occurred prior to that day, provided that the underlying activity would not be sanctionable
at the time of the payment and the transaction does not involve persons on the SDN List.
Non-U.S. persons should ensure that the only sanctions implicated by the underlying
activity are sanctions that have been lifted pursuant to the JCPOA prior to paying claims
related to Iran. To the extent a claim payment involves a U.S. person, the payment of
such claim remains prohibited even after Implementation Day and requires an
authorization from OFAC prior to payment. [01-16-2016]
D. 3. Can insurers or reinsurers provide underwriting services, insurance, or reinsurance
to NITC or Islamic Republic of Iran Shipping Lines (IRISL) vessels or vessels
owned by non-U.S. persons when chartered by NITC or IRISL?
Beginning on Implementation Day, it is not sanctionable for non-U.S. persons to provide
underwriting services, insurance, or reinsurance to NITC or IRISL vessels or vessels
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
25
owned by non-U.S. persons when chartered by NITC or IRISL, provided that the
transactions do not involve persons on the SDN List or conduct described in FAQ A.3.iiiii.
U.S. persons continue to be generally prohibited from exporting goods, services, or
technology directly or indirectly to Iran, and it continues to be prohibited for U.S. persons
to provide underwriting services, insurance, or reinsurance to NITC or IRISL, including
extending insurance coverage to, or paying claims involving, NITC or IRISL. For
additional guidance for U.S. insurers participating in worldwide insurance markets
through global insurance policies, please see FAQ 102. [01-16-2016]
D. 4. Can non-U.S. insurers or reinsurers provide underwriting services, insurance, or
reinsurance for a vessel that has been chartered by a non-U.S. person or owned by a
non-U.S. person that is transporting crude oil from Iran?
Yes. Beginning on Implementation Day, it is not sanctionable for non-U.S. persons to
provide underwriting services, insurance, or reinsurance for vessels transporting crude oil
from Iran, provided that the transactions do not involve persons on the SDN List or
conduct described in FAQ A.3.ii-iii.
U.S. persons continue to be generally prohibited from exporting goods, services, or
technology directly or indirectly to Iran, including extending insurance coverage to, or
paying claims involving, the transportation of Iranian crude. For additional guidance for
U.S. insurers operating in the global market, please see FAQ 102. [01-16-2016]
D. 5. Can U.S. insurers or reinsurers provide underwriting services, insurance, or
reinsurance related to activities by non-U.S. persons that are no longer sanctionable
following Implementation Day?
No. The sanctions lifting provided for in the JCPOA largely applies to the activities of
non-U.S. persons. After Implementation Day, U.S. persons continue to be generally
prohibited from exporting goods, services, or technology directly or indirectly to Iran that
are not exempt from regulation or authorized by OFAC, including extending insurance
coverage to, or paying claims involving, Iran. For additional guidance for U.S. insurers
operating in the global market, please see FAQ 102. [01-16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
26
D. 6. What role can U.S. insurers and reinsurers have in Protection and Indemnity (P&I)
clubs in order to remain compliant with U.S. sanctions?
The sanctions lifting provided for in the JCPOA largely applies to the activities of non-
U.S. persons. After Implementation Day, U.S. persons continue to be generally
prohibited from exporting goods, services, or technology directly or indirectly to Iran,
including extending insurance coverage to, or paying claims involving, Iran, with the
exception of transactions that are exempt or authorized by OFAC. For additional
guidance for U.S. insurers operating in the global market, please see FAQ 102. [01-16-
2016]
D. 7. Can U.S. insurers provide travel insurance to individuals traveling to Iran?
Yes, travel insurance continues to be exempt from regulation by OFAC as ordinarily
incident to travel. Please see FAQ 104. [01-16-2016]
E. SHIPPING, SHIPBUILDING, AND PORT SECTORS
E. 1. The JCPOA provides that the United States will lift certain sanctions on
transactions with Iran’s shipping and shipbuilding sectors and port operators on
Implementation Day. Does this mean that non-U.S. persons can engage in
transactions with Iran’s shipping and shipbuilding sectors?
Yes. As a result of the U.S. commitments specified in sections 4.4 of Annex II and 17.1
of Annex V of the JCPOA, on Implementation Day, the United States lifted secondary
sanctions on Iran’s shipping and shipbuilding sectors and port operators in Iran, including
sanctions on the sale, supply, or transfer to or from Iran of significant goods or services
used in connection with Iran’s shipping and shipbuilding sectors (including port services
such as bunkering, inspection, classification, and financing); sanctions on transactions
with entities determined to be part of the shipping or shipbuilding sectors of Iran
(including IRISL, South Shipping Line, and NITC), and persons determined to be Iranian
port operators (including the port operator(s) of Bandar Abbas, provided that such
persons are no longer controlled by a person on the SDN List); and sanctions on the
provision of associated services for the foregoing. As a result, beginning on
Implementation Day, non-U.S. persons are no longer subject to sanctions for engaging in
such activities, provided that the transactions do not involve persons on the SDN List or
conduct described in FAQ A.3.ii-iii.
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
27
In addition, it is no longer sanctionable for non-U.S. persons to own, operate, control, or
insure a vessel used to transport crude oil, petroleum products (including refined
petroleum products), petrochemical products, or natural gas (including liquefied natural
gas) to or from Iran, or to sell, lease, or provide vessels to Iran (including to IRISL,
NITC, and South Shipping Lines or their affiliates), provided that transactions do not
involve persons on the SDN List or conduct described in FAQ A.3.ii-iii.
U.S. persons continue to be generally prohibited under the ITSR from involvement in the
activity described above. In addition, transactions related to the above-mentioned
activity are prohibited from transiting the U.S. financial system. [01-16-2016]
E. 2. The JCPOA provides for the lifting of U.S. sanctions on transactions with persons
determined to be port operators in Iran, to include the operator(s) of Bandar Abbas
(provided that the port operator(s) of Bandar Abbas is no longer controlled by a
person on the SDN List). Are transactions with Tidewater Middle East Co. still
considered sanctionable?
Based on publicly available information, as of Implementation Day (January 16, 2016), it
appears Tidewater Middle East Co. (Tidewater) is not the port operator of Bandar Abbas.
Accordingly, secondary sanctions would not apply solely on the basis of engaging in
transactions, with or conducting trade through, Bandar Abbas so long as the transactions
or trade does not involve a person on the SDN List.
Tidewater, a port operating company on the SDN List that is owned by Iran’s Islamic
Revolutionary Guard Corps (IRGC), remains on the SDN List after Implementation Day,
and transactions by U.S. and non-U.S persons with Tidewater continue to be
sanctionable. As always, persons should exercise caution to avoid engaging in
transactions with persons on the SDN List. [01-16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
28
F. GOLD AND OTHER PRECIOUS METALS
F. 1. The JCPOA provides that the United States will lift secondary sanctions related to
Iran’s trade in gold and other precious metals. Does this mean that non-U.S.
persons can buy gold from and/or sell gold to Iran?
Yes. Pursuant to its commitment under sections 4.5 of Annex II and 17.1 of Annex V of
the JCPOA, the United States lifted sanctions on the direct or indirect sale, supply,
export, or transfer to or from Iran, including the Government of Iran, by non-U.S. persons
of gold and other precious metals, as well as associated services that are required to
facilitate such transactions. As a result, non-U.S. persons are no longer subject to
sanctions for engaging in such activities or transactions, provided that they do not involve
persons on the SDN List or conduct described in FAQ A.3.ii-iii.
For the purposes of implementing U.S. commitments under the JCPOA and these FAQs,
the term “precious metals” includes silver (including silver plated with gold or platinum,
unwrought or in semi-manufactured forms, or in powder form); gold (including gold
plated with platinum, unwrought or in semi-manufactured forms, or in powder form);
base metals or silver, clad with gold, not further worked than semi-manufactured;
platinum, unwrought or in semi-manufactured forms, or in powder form; iridium;
osmium; palladium; rhodium; ruthenium; base metals, silver or gold, clad with platinum,
not further worked than semi-manufactured; and waste and scrap of precious metal or of
metal clad with precious metals, other waste and scrap containing precious metal or
precious-metal compounds, of a kind used principally for the recovery of precious metal.
[01-16-2016]
G. SOFTWARE AND METALS
G. 1. The JCPOA provides that, on Implementation Day, the United States will lift
sanctions related to trade with Iran in certain materials and software. What
materials are included within the scope of the lifting?
Pursuant to its commitment under sections 4.6 of Annex II and 17.2 of Annex V of the
JCPOA, the United States lifted secondary sanctions on the direct or indirect sale, supply,
or transfer to or from Iran of graphite, raw or semi-finished metals such as aluminum and
steel, coal, and software for integrating industrial processes, including the provision of
associated services in connection with the foregoing. As a result, beginning on
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
29
Implementation Day, non-U.S. persons are no longer subject to sanctions for engaging in
such activities, provided such transactions are consistent with the JCPOA (see FAQ G.2)
and do not involve persons on the SDN List or conduct described in FAQ A.3.ii-iii. [01-
16-2016]
G. 2. How does United States interpret the phrase “consistent with the JCPOA” in the
context of the lifting of sanctions on trade with Iran in certain materials and
software?
For purposes of the lifting of sanctions on Implementation Day on trade by non-U.S.
persons with Iran in certain materials and software (see FAQ G.1), the United States
considers transactions involving the following to be inconsistent with the JCPOA:
(1) persons on the SDN List, including the IRGC; (2) transfers of such materials or
software for use in the military or ballistic missile programs of Iran; and (3) transfers that
have not been approved by the procurement channel established by the JCPOA and
paragraph 16 of UN Security Council Resolution 2231 (2015) if the transfer of the item is
subject to the procurement channel. [01-16-2016]
G. 3. Does the lifting of sanctions related to materials and software also lift U.S. export
control requirements and export prohibitions under the ITSR?
No. The lifting of sanctions discussed in FAQ G.2 above relates only to transactions by
non-U.S. persons in goods that are not subject to U.S. export controls. U.S. export
controls, including all licensing requirements, and prohibitions under the ITSR continue
to apply to exports and reexports by U.S. persons or from the United States to Iran or the
Government of Iran, as well as reexports by non-U.S. persons of items with 10 percent or
more U.S.-controlled content to Iran or the Government of Iran, if undertaken with
knowledge or reason to know that the reexportation is intended specifically for Iran or the
Government of Iran (see FAQ M.9). [01-16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
30
H. AUTOMOTIVE SECTOR
H. 1. The JCPOA provides that the United States will lift secondary sanctions on the sale,
supply, or transfer of goods and services used in connection with Iran’s automotive
sector. Does this mean that non-U.S. persons can sell to Iran goods and services
used in connection with the automotive sector?
Yes. Under the JPOA, U.S. sanctions on the sale, supply, or transfer by non-U.S. persons
of goods and services used in connection with Iran’s automotive sector were temporarily
suspended. On Implementation Day, pursuant to its commitment under sections 4.7 of
Annex II and 17.1 of Annex V of the JCPOA, the United States lifted secondary
sanctions on the direct or indirect sale, supply, or transfer to Iran of goods or services
used in connection with the automotive sector of Iran, including the provision of
associated services. As a result, beginning on Implementation Day, non-U.S. persons are
no longer subject to sanctions for engaging in such activities or transactions provided that
they do not involve persons on the SDN List or conduct described in FAQ A.3.ii-iii. See
FAQs 310, 311, 316, and 317 for a discussion of “Iran’s automotive sector” and goods
and services associated with Iran’s automotive sector. [01-16-2016]
H. 2. Can U.S. auto manufacturers export or reexport U.S.-origin finished vehicles or
U.S.-origin auto parts to Iran?
No. U.S. persons as defined in section 560.314 of the ITSR, including U.S. auto
manufacturers, continue to be generally prohibited from the exportation, reexportation,
sale, or supply, directly or indirectly, from the United States of any goods, technology, or
services to Iran’s automotive sector or the Government of Iran. [01-16-2016]
H. 3. Can non-U.S. persons reexport U.S.-origin finished vehicles or U.S.-origin auto
parts to Iran?
Non-U.S. persons continue to be prohibited from reexporting from a third country to Iran,
directly or indirectly, any goods, technology, or services that have been exported from the
United States if they know or have reason to know that the reexportation is intended
specifically for Iran or the Government of Iran and the items are controlled for export
from the United States to Iran. Additionally, non-U.S. persons – including U.S.-owned
or -controlled foreign entities (see FAQ K.2) – continue to be prohibited from reexporting
to Iran or the Government of Iran items containing 10 percent or more U.S.-controlled
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
31
content if undertaken with knowledge or reason to know that the reexportation is
intended specifically for Iran or the Government of Iran. See also FAQ M.9. Additional
export controls administered by the Department of Commerce may also apply. [01-16-
2016]
I. DESIGNATIONS AND OTHER SANCTIONS LISTINGS
I. 1. The JCPOA provides that the United States will remove certain individuals and
entities from the SDN List on Implementation Day. What did this entail? What is
the effect on those removed from the SDN List and what happens to those remaining
on the SDN List?
Pursuant to U.S. commitments under sections 4.8.1 of Annex II and 17.3 of Annex V of
the JCPOA, on Implementation Day, the individuals and entities set out in Attachment 3
to Annex II were removed from the SDN List, FSE List, and/or NS-ISA List. Non-U.S.
persons are no longer subject to secondary sanctions for engaging in transactions with the
over 400 individuals and entities removed from the SDN List on Implementation Day,
provided that the transactions do not otherwise involve persons that remain or are placed
on the SDN List or conduct described in FAQ A.3.ii-iii. For more information on
individuals and entities set out in Attachment 3 to Annex II who are marked with an
asterisk because they have been identified previously by OFAC as meeting the definition
of the term “Government of Iran” or “Iranian financial institution,” see FAQ I.3.
After Implementation Day, Iranian and Iran-related persons on the SDN List remain
subject to secondary sanctions (see FAQ A.6), and secondary sanctions continue to attach
to transactions involving such persons, even if the underlying activity is one for which
sanctions have been lifted under the JCPOA. [01-16-2016]
I. 2. What is the E.O. 13599 List and how should U.S. persons treat individuals and
entities on this list?
To assist U.S. persons in meeting their obligations under the ITSR, OFAC has made
available on its website a List of Persons Identified as Blocked Solely Pursuant to
Executive Order 13599 (E.O. 13599 List). The purpose of this list is to clarify that,
regardless of their removal from the SDN List, persons that OFAC previously identified
as meeting the definition of the Government of Iran or an Iranian financial institution
continue to meet those definitions and continue to be persons whose property and
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
32
interests in property are blocked pursuant to Executive Order 13599 and section 560.211
of the ITSR (see FAQ I.3). Unless an exemption or express OFAC authorization applies,
U.S. persons, wherever located, are prohibited from engaging in any transaction with, and
must continue to block the property and interests in property of, persons on the E.O.
13599 List, as well as any other person meeting the definition of the Government of Iran
or an Iranian financial institution. [01-16-2016]
I. 3. Do identified Government of Iran individuals and entities and Iranian financial
institutions removed from the SDN List on Implementation Day pursuant to the
JCPOA (i.e. the asterisked individuals and entities listed in Attachment 3 to Annex
II of the JCPOA) remain subject to U.S. blocking? Do U.S. persons still have to
block transactions with persons removed from the SDN List on Implementation
Day?
Attachment 3 to Annex II of the JCPOA sets out the individuals and entities that were
removed from the SDN List, FSE List, and/or NS-ISA List, as appropriate, on
Implementation Day pursuant to the U.S. commitment under sections 4.8.1 of Annex II
and 17.3 of Annex V of the JCPOA. A number of the individuals and entities listed in
Attachment 3 to Annex II are marked with an asterisk next to their name, denoting that
they have been previously identified by OFAC as meeting the definition of the term
“Government of Iran” or “Iranian financial institution,” as set forth, in Executive Order
13599 and sections 560.304 and 560.324, respectively of the ITSR. Beginning on
Implementation Day, secondary sanctions no longer apply to transactions involving these
entities. However, U.S. persons continue to have an obligation under Executive Order
13599 and the ITSR to block the property and interests in property of all individuals and
entities that meet these definitions, regardless of whether the individual or entity has been
identified by OFAC or included on any OFAC-administered sanctions list, including the
E.O. 13599 List (see FAQ I.2). U.S. persons also continue to be prohibited generally
from engaging in transactions or dealings with these individuals and entities pursuant to
the ITSR.
The property and interests in property of those persons in Attachment 3 to Annex II of the
JCPOA without an asterisk next to their name are no longer subject to blocking on
Implementation Day so long as they do not meet the definition of the “Government of
Iran” or “Iranian financial institution” set out in the ITSR and Executive Order 13599.
U.S. persons continue to be prohibited generally from engaging in transactions involving
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
33
Iran pursuant to the ITSR, with the exception of transactions that are exempt from
regulation or authorized by OFAC. [01-16-2016]
I. 4. Do non-U.S. persons face secondary sanctions exposure for dealing with individuals
and entities on the E.O. 13599 List?
No. Secondary sanctions do not attach to transactions involving persons on the E.O.
13599 List, provided that the activities do not involve persons on the SDN List or
conduct described in FAQ A.3.ii-iii. [01-16-2016]
I. 5. On Implementation Day, are sanctions lifted on the individuals and entities listed
in Attachment 4 to Annex II of the JCPOA?
No. The individuals and entities set out in Attachment 4 to Annex II of the JCPOA will
remain on the SDN List until Transition Day unless the U.S. government takes action to
remove them before that time. Transactions with these individuals or entities continue to
be sanctionable until they are removed from the SDN List. [01-16-2016]
I. 6. Could foreign financial institutions still be sanctioned under CISADA for
engaging in transactions with Iranian persons?
Yes, if such persons are on the SDN List after Implementation Day. While sanctions
under section 104(c)(2)(E)(ii) of CISADA no longer apply to transactions with
individuals and entities removed from the SDN List on Implementation Day, CISADA
104(c)(2)(E)(ii) remains in place and significant transactions with persons designated in
connection with Iran’s proliferation of WMD or their means of delivery or Iran’s support
for international terrorism – i.e., persons on the SDN List with the [IFSR] program tag –
remain sanctionable (see FAQ A.6). [01-16-2016]
J. COMMERCIAL PASSENGER AVIATION
J. 1. How has the commitment in the JCPOA to allow the export, reexport, sale, lease, or
transfer of commercial passenger aircraft and related parts and services to Iran
been implemented?
OFAC issued a Statement of Licensing Policy (SLP), effective on Implementation Day,
establishing a favorable licensing policy regime through which U.S. persons and, where
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
34
there is a nexus to U.S. jurisdiction, non-U.S. persons may request specific authorization
from OFAC to engage in transactions for the export, reexport, sale, lease, or transfer of
commercial passenger aircraft and related parts and services to Iran, provided that the
licensed items are used exclusively for commercial passenger aviation. Specific licenses
issued pursuant to the SLP will include appropriate conditions to ensure that licensed
activities do not involve, and no licensed aircraft, goods, or services are re-sold or retransferred
to, any person on OFAC’s SDN List. [01-16-2016]
J. 2. What type of aircraft can be provided to Iran pursuant to the JCPOA commitment?
Specific licenses may be issued for U.S. persons or, where there is a nexus to U.S.
jurisdiction, non-U.S. persons to export, reexport, sell, lease, or transfer to Iran U.S.-
origin commercial passenger aircraft or commercial passenger aircraft that contains 10
percent or more U.S.-controlled content. For more information on how to calculate U.S.-
controlled content, see section 560.420 of the ITSR. The types of aircraft that may be
approved under the SLP include wide-body, narrow-body, regional, and commuter
aircraft used for commercial passenger aviation. The types of aircraft not eligible for
licensing under the SLP include cargo aircraft, state aircraft, unmanned aerial vehicles,
military aircraft, and aircraft used for general aviation or aerial work. [01-16-2016]
J. 3. What services would be considered ordinarily incident and necessary to a licensed
transaction for the export, reexport, sale, lease, or transfer of commercial passenger
aircraft and related parts and services to Iran?
Under section 560.405 of the ITSR, U.S. persons are authorized to engage in transactions
that are ordinarily incident to a licensed transaction and necessary to give effect thereto.
Services that are ordinarily incident and necessary to give effect to a licensed export,
reexport, sale, lease, or transfer of a commercial passenger aircraft to Iran, or a licensed
export, reexport, sale, lease, or transfer of related parts and services to Iran, include
transportation, legal, insurance, shipping, delivery, and financial payment services
provided in connection with the licensed export transaction. For example, a U.S.
person’s provision of insurance to cover the shipment of a licensed component from a
U.S. manufacturer to an Iranian customer would be ordinarily incident to the licensed
export transaction. In contrast, a U.S. person’s provision of insurance to cover the
component over a period of years after it has been exported to Iran would not be
ordinarily incident to the licensed export transaction and would require separate
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
35
authorization from OFAC. See FAQ J.4 for additional information on associated services
that can be separately authorized. [01-16-2016]
J. 4. What types of associated services could be authorized in licenses issued to U.S.
persons related to the export, reexport, sale, lease, or transfer of commercial
passenger aircraft and related parts and services to Iran?
Applications submitted pursuant to the SLP should include all the parties involved in the
transactions and describe in detail all related transactions and dealings the parties
anticipate undertaking that would otherwise be prohibited by 31 C.F.R. part 560. These
transactions and dealings may include, for example, the provision of warranty,
maintenance, repair services, safety-related inspections, and training related to
commercial passenger aircraft and spare parts and components for such aircraft exported
to Iran pursuant to a specific license issued under the SLP, provided that the items and
services for which authorization is sought are to be used exclusively for commercial
passenger aviation. [01-16-2016]
J. 5. Can U.S. persons seek a specific license to provide associated services that are not
otherwise authorized by an existing specific license for the export, reexport, sale,
lease, or transfer of commercial passenger aircraft or related parts and services to
Iran?
OFAC will consider applications from U.S. persons to provide associated services
otherwise prohibited by 31 C.F.R. part 560 that are not within the scope of an existing
specific license issued pursuant to the SLP, and are not ordinarily incident and necessary
to give effect to a licensed transaction pursuant to section 560.405 of the ITSR. Requests
to provide such associated services must relate to a specific export, reexport, sale, lease,
or transfer of a commercial passenger aircraft or related parts and services. This means,
for example, that OFAC will consider applications under the SLP for a U.S. financial
institution to finance the sale of a particular commercial passenger aircraft, but not an
application to provide aircraft financing services in general. See FAQ J.6 for information
on the provision of associated services by non-U.S. persons. [01-16-2016]
J. 6. Do non-U.S. persons need a specific license to provide associated services in
connection with commercial passenger aircraft or parts and components for such
aircraft that have been licensed for export or reexport to Iran? Or for commercial
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
36
passenger aircraft or parts and components for such aircraft that have not been
licensed for export or reexport to Iran?
OFAC authorization is not required for non-U.S. persons to provide associated services to
Iranian parties, provided that the transaction does not involve U.S. persons or the export
or reexport to Iran of items that would require a license for export from the United States
to Iran, is conducted outside of U.S. jurisdiction, and does not involve the U.S. financial
system. However, even after Implementation Day, secondary sanctions will continue to
attach to transactions with Iranian or Iran-related individuals or entities that remain or are
placed on the SDN List.
OFAC will consider applications under the SLP from non-U.S. persons to provide
associated services that would otherwise be prohibited by 31 C.F.R. part 560, such as
those involving the export or reexport of items from the United States to Iran or the
reexport of U.S.-controlled items from a third-country to Iran that require a license under
section 560.205 of the ITSR. [01-16-2016]
J. 7. Does the JCPOA impact the ability of airlines to fly into or out of Iran? Are U.S.
persons allowed to fly on Iranian airlines?
The JCPOA does not impact the prohibition on U.S. airlines operating flights to or from
Iran. Secondary sanctions continue to attach to significant transactions with Mahan Air
and other Iranian persons on the SDN List (see FAQ A.3.iii).
U.S. persons are allowed to engage in transactions that are ordinarily incident to travel to
or from Iran, including flying on Iranian airlines, with the exception of airlines, such as
Mahan Air, that are designated under the Global Terrorism Sanctions Regulations, 31
C.F.R. part 594 (GTSR). Airlines designated pursuant to the GTSR are included on
OFAC’s SDN List (available at http://sanctionssearch.ofac.treas.gov/) and are labeled
with the program tag [SDGT]. [01-16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
37
J. 8. Is additional authorization from the Department of Commerce be needed for the
export, reexport, sale, lease, or transfer of commercial passenger aircraft and spare
parts and components for such aircraft to Iran, if such activities are licensed by
OFAC under the SLP?
Transactions authorized by OFAC pursuant to the SLP do not need separate authorization
from the Department of Commerce, unless the action or activity involves an item
(including information) that is prohibited by, or otherwise requires a license under, part
744 of the Export Administration Regulations (EAR) or participation in any transaction
involving a person whose export privileges have been denied pursuant to parts 764 or 766
of the EAR. Exports or reexports to individuals and entities listed on the Department of
Commerce’s Denied Persons List and, in some cases, the Entity List will require separate
authorization from the Department of Commerce and further coordination between
OFAC and the U.S. Department of State. The Denied Persons List may be accessed at
http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-co…-
list and the Entity List may be accessed at
http://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-co….
Applicants seeking to engage in transactions that would require separate authorization
from the Department of Commerce should submit an application to it when submitting an
application to OFAC pursuant to the SLP; the application to OFAC should also identify
any individuals or entities that may give rise to a requirement for a separate authorization
from the Department of Commerce. [01-16-2016]
J. 9. Why did OFAC issue General License I (GL I)?
As a general matter, unless authorized by OFAC, U.S. persons are prohibited from
entering into contracts – contingent or otherwise – involving Iran or the Government of
Iran. In addition, U.S. persons are prohibited from engaging in activities that are
ordinarily incident to the negotiation of or entry into a contract involving Iran or the
Government of Iran if such activities implicate the prohibitions of the ITSR (e.g.,
activities that may involve the importation of services from, or exportation of services to,
an Iranian party).
Authorizing U.S. persons to enter into, and to engage in transactions that are ordinarily
incident to the negotiation of and the entry into, contingent contracts for activities eligible
for authorization under the Statement of Licensing Policy for Activities Related to the
Export or Re-export to Iran of Commercial Passenger Aircraft and Related Parts and
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
38
Services (SLP) will allow for more efficient processing of specific license applications
for the export or re-export to Iran of commercial passenger aircraft and related parts and
services submitted under the SLP. However, GL I does not authorize transactions related
to the negotiation of contracts – contingent or otherwise – involving individuals and
entities on the SDN list.
Non-U.S. persons are not prohibited under the ITSR from entering into contracts –
contingent or otherwise – involving Iran or the Government of Iran that are eligible for
authorization under the SLP. However, prior to performing activities eligible for
authorization under the SLP, non-U.S. persons must obtain a specific license from
OFAC. [03-24-16]
J. 10. Does GL I authorize the export or re-export of commercial passenger aircraft
and/or related parts or services to Iran?
No. GL I does not authorize the export or re-export of any aircraft or related parts or
services to Iran. Persons interested in exporting or re-exporting commercial passenger
aircraft and related parts and services to Iran under the SLP are required to submit a
specific license application to OFAC. [03-24-16]
J. 11. What information should be included in specific license applications submitted
under the SLP?
Persons seeking to export or re-export commercial passenger aircraft and/or related parts
and services under the SLP should include as much detail about the transaction as
possible. As an initial matter, applications must include the following information: 1) the
types and number of aircraft being exported or leased; 2) the Export Control
Classification Number(s) for the aircraft, related parts, and/or technology being exported
or leased; 3) the Iranian airline receiving the aircraft; 4) the proposed end-use of the
aircraft; and 5) any other information that may be relevant to the processing of the
request. [03-24-16]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
39
J. 12. Is the negotiation of and entry into a Nondisclosure Agreement (NDA) in connection
with the negotiation of a contingent contract for activities eligible for authorization
under the SLP authorized by GL I?
Yes. However, the enforcement of any breach of an NDA against an Iranian party does
not fall within the scope of the authorization in GL I and may require separate
authorization. [03-24-16]
K. FOREIGN ENTITIES OWNED OR CONTROLLED BY U.S. PERSONS
K. 1. The JCPOA provides for the licensing of non-U.S. entities that are owned or
controlled by a U.S. person (“U.S.-owned or -controlled foreign entities”) to engage
in activities with Iran that are consistent with the JCPOA and U.S. law. How is this
commitment being implemented?
The commitment to license U.S.-owned or -controlled foreign entities to engage in
activities with Iran that are consistent with the JCPOA and U.S. law has been
implemented through OFAC’s issuance of General License H: Authorizing Certain
Transactions Relating to Foreign Entities Owned or Controlled by a United States Person
(GL H). GL H was published on OFAC’s website on January 16, 2016. [01-16-2016]
K. 2. What is considered a U.S.-owned or -controlled foreign entity for purposes of the
U.S. commitment under the JCPOA to license certain activities involving Iran?
An entity established or maintained outside the United States is “owned or controlled” by
a U.S. person if the U.S. person: (1) holds a 50 percent or greater equity interest by vote
or value in the entity; (2) holds a majority of seats on the board of directors of the entity;
or (3) otherwise controls the actions, policies, or personnel decisions of the entity. See
section 560.215 of the ITSR and FAQ K.17. [01-16-2016; updated on 06-08-2016]
K. 3. What activities can U.S.-owned or -controlled foreign entities undertake pursuant to
GL H?
Pursuant to GL H, U.S.-owned or -controlled foreign entities are permitted to engage in
transactions with the Government of Iran or any person subject to the jurisdiction of the
Government of Iran that would otherwise be prohibited by section 560.215 of the ITSR
(i.e., activities that would be prohibited pursuant to the ITSR if engaged in by a U.S.
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
40
person or in the United States), with the exception of transactions specified in paragraph
(c) of GL H. In particular, paragraph (c) provides that U.S.-owned or -controlled foreign
entities engaging in transactions pursuant to GL H may not export or reexport U.S.-origin
goods to Iran without separate authorization from OFAC, as further described in FAQ
K.13. The authorization provided under GL H is not limited to specific economic sectors
or industries. [01-16-2016]
K. 4. For purposes of the U.S. commitment in section 5.1.2 of Annex II of the JCPOA,
what activities are consistent with the JCPOA and applicable U.S. laws and
regulations?
Activities by U.S.-owned or -controlled foreign entities that are within the scope of GL H
will be deemed to be consistent with the JCPOA and the laws and regulations
administered by OFAC. Individuals and entities acting pursuant to GL H remain
responsible for complying with other applicable U.S. laws and regulations, including, for
example, the Federal Food, Drug, and Cosmetic Act.
Transactions that are not authorized under GL H because they are inconsistent with the
JCPOA and/or U.S. law include transactions involving: (1) the direct or indirect
exportation or reexportation of goods, technology, or services from the United States
(without separate authorization from OFAC); (2) any transfer of funds to, from, or
through the U.S. financial system; (3) any individual or entity on the SDN List or any
activity that would be prohibited by non-Iran sanctions administered by OFAC if engaged
in by a U.S. person or in the United States; (4) any individual or entity identified on the
FSE List; (5) any activity involving any item subject to the Export Administration
Regulations (EAR) that is prohibited by, or requires a license under, part 744 of the EAR;
or participation in any transaction with a person whose export privileges have been
denied pursuant to part 764 or 766 of the EAR (without authorization from the
Department of Commerce); (6) any military, paramilitary, intelligence, or law
enforcement entity of the Government of Iran, or any official, agent, or affiliate thereof;
(7) any activity that is sanctionable under Executive Order 12938 or 13382 (relating to
Iran’s proliferation of weapons of mass destruction and their means of delivery, including
ballistic missiles); Executive Order 13224 (relating to international terrorism); Executive
Order 13572 or 13582 (relating to Syria); Executive Order 13611 (relating to Yemen); or
Executive Order 13553 or 13606, or section 2 or 3 of Executive Order 13628 (relating to
Iran’s commission of human rights abuses against its citizens); or (8) any nuclear activity
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
41
involving Iran that is subject to the JCPOA procurement channel and that has not been
approved through that procurement channel process. [01-16-2016]
K. 5. Who could be held liable for transactions conducted by a U.S.-owned or -controlled
foreign entity that are outside the scope of GL H?
A U.S. person will continue to be liable for civil penalties provided for in section 206(b)
of the International Emergency Economic Powers Act if any foreign entity that it owns or
controls engages in activity outside the scope of GL H or other relevant authorization
provided by OFAC that would violate the prohibition set forth in section 560.215 of the
ITSR. See section 560.701(a)(3) of the ITSR. [01-16-2016]
K. 6. What are U.S. persons permitted to do with respect to transactions undertaken
pursuant to GL H?
GL H authorizes U.S. persons to engage in “activities related to the establishment or
alteration of operating policies and procedures of a United States entity or a U.S.-owned
or -controlled foreign entity” to the extent necessary to allow a U.S.-owned or -controlled
foreign entity to engage in transactions with Iran that are authorized by GL H. This
authorization in GL H is intended to cover the involvement of U.S. person board
members, senior management, and employees of either a U.S. parent company or a U.S.-
owned or -controlled foreign entity in the establishment or alteration of operating policies
and procedures of the U.S. parent company or any of its owned or controlled foreign
entities, to the extent necessary to allow any of the U.S.-owned or -controlled foreign
entities to engage in transactions with Iran authorized under GL H. The authorization for
U.S. persons is also intended to cover U.S. persons who may be hired as outside legal
counsel or consultants to draft, alter, advise, or consult on such operating policies and
procedures.
Under this provision of GL H, U.S. persons, including senior management of a U.S.
parent company or its owned or controlled foreign entities, may be involved in the initial
determination to engage in activities with Iran authorized by GL H, as well as the
establishment or alteration of the necessary policies and procedures. However, GL H
does not authorize U.S. person involvement in the ongoing Iran-related operations or
decision making of its owned or controlled foreign entity engaging in activities with Iran
authorized by GL H after these actions are taken. U.S. persons may not be involved in
the Iran-related day-to-day operations of a U.S.-owned or -controlled foreign entity,
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
42
including by approving, financing, facilitating, or guaranteeing any Iran-related
transaction by the foreign entity. See sections 560.208 and 560.417 of the ITSR. [01-16-
2016]
K. 7. Under GL H, are U.S. persons allowed to provide training on the new or revised
policies and procedures?
Yes. GL H authorizes U.S. persons, including employees and outside legal counsel and
consultants, to provide training, advice, and counseling on the new or revised operating
policies and procedures, provided that these services are not provided to facilitate
transactions in violation of U.S. law. For example, U.S. person employees of a U.S.
parent company or a U.S.-owned or -controlled foreign entity are authorized to provide
training on the new or revised operating policies and procedures to employees of a U.S.-
owned or -controlled foreign entity covered by such policies. They are also authorized to
provide training on the revised operating policies and procedures to employees of the
U.S. parent company. [01-16-2016]
K. 8. What are U.S. persons who work in U.S.-owned or -controlled foreign entities
permitted to do with respect to transactions undertaken pursuant to GL H?
U.S. persons working in U.S.-owned or -controlled foreign entities are authorized under
GL H to engage in activities related to the establishment or alteration of corporate
policies and procedures of the U.S. parent company of the U.S.-owned or -controlled
foreign entities, as well as corporate policies and procedures of the U.S.-owned or
-controlled foreign entities, to the extent the establishment or alteration of such policies is
necessary to allow the U.S.-owned or -controlled foreign entity to engage in transactions
authorized under GL H. This authorization extends to the involvement of U.S. persons in
the initial determination to engage in activities with Iran authorized by GL H; however, it
does not extend to the involvement of U.S. persons in the Iran-related day-to-day
operations of a U.S.-owned or -controlled foreign entity engaging in activities with Iran
authorized by GL H (see FAQs K.6 and K.7). With the exception of the authorizations in
GL H, U.S. persons remain prohibited from engaging in or facilitating transactions or
dealings involving Iran that are not exempt from regulation or authorized by OFAC. [01-
16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
43
K. 9. GL H authorizes U.S. persons to “make available” any automated and globally
integrated computer, accounting, email, telecommunications, or other business
support system, platform, database, application, or server necessary to store, collect,
transmit, generate, or otherwise process documents or information related to
transactions by foreign entities they own or control that are authorized by GL H
(hereinafter referred to as “Authorized Business Support Systems”). Does this
allow U.S. parent companies to provide foreign entities they own or control with
access to Authorized Business Support Systems that are owned or operated by
third-party service providers?
Yes. The authorization in GL H permits U.S. parent companies to make available to
foreign entities they own or control Authorized Business Support Systems that are owned
and/or operated for the U.S. parent company on a contract basis by one or more thirdparty
service providers. Likewise, U.S. person third-party service providers are
authorized to make available to a U.S.-owned or -controlled foreign entity Authorized
Business Support Systems that they provide to the U.S. parent company on a contract
basis. [01-16-2016]
K. 10. What does “automated” mean in reference to the Authorized Business Support
Systems enumerated in GL H?
In the context of GL H, the term “automated” refers to Authorized Business Support
Systems that operate passively and without human intervention to facilitate the flow of
data between and among the U.S. parent company and its owned or controlled foreign
entities. For example, an enterprise resource planning (ERP) system that utilizes a U.S.-
based server – without any human intervention in the United States – to generate a
purchase order initiated by a Dubai-based, non-U.S. person employee of a U.S.-owned or
-controlled foreign entity would be considered “automated” for the purposes of GL H. In
contrast, if the ERP system required the intervention of an individual located in the
United States to complete a request initiated by a Dubai-based, non-U.S. person
employee of a U.S.-owned or -controlled foreign entity, such as a U.S. person performing
data entry or internal processing for the creation of a customer record, such system would
not be considered “automated” for the purposes of GL H. See FAQ K.12 for additional
information on human intervention vis-à-vis Authorized Business Support Systems. [01-
16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
44
K. 11. What does “globally integrated” mean in reference to the Authorized Business
Support Systems enumerated in GL H?
In the context of GL H, the term “globally integrated” refers to an Authorized Business
Support System that is broadly available to, and in general use by, the U.S. parent
company’s global organization, including the U.S. parent company and its owned or
controlled foreign entities. For example, a sales lead database maintained on a server at a
U.S. parent company that is broadly available to, and in general use by, the U.S. parent
company’s non-U.S. entities would be considered “globally integrated” for the purposes
of GL H. In contrast, a similar database containing information maintained in the United
States that is not broadly available to the U.S. parent company’s non-U.S. entities or lines
of business performed by such entities would not be considered “globally integrated” for
the purposes of GL H. [01-16-2016]
K. 12. Is all human intervention vis-à-vis Authorized Business Support Systems outside the
scope of GL H?
No. Activities related to the establishment or maintenance of Authorized Business
Support Systems that meet the requirements of GL H – including routine or emergency
maintenance by U.S. persons – are authorized as ordinarily incident and necessary to give
effect to transactions authorized by paragraph (b) of GL H. See section 560.405 of the
ITSR. [01-16-2016]
K. 13. Can U.S.-owned or -controlled foreign entities rely on GL H to export U.S.-origin
goods to Iran?
No. GL H does not provide any authorization relating to the exportation or reexportation
of U.S.-origin goods to Iran. Beginning on Implementation Day, unless the transactions
are exempt from regulation or authorized by OFAC, U.S.-owned or -controlled foreign
entities continue to be prohibited from the exportation, reexportation, sale, or supply,
directly or indirectly, from the United States of any goods, technology, or services if the
items are destined for Iran or the Government of Iran at the time they leave the United
States. In addition, non-U.S. persons – including U.S.-owned or -controlled foreign
entities – continue to be prohibited from reexporting from a third country, directly or
indirectly, any goods, technology, or services that have been exported from the United
States if they know or have reason to know that the reexportation is intended specifically
for Iran or the Government of Iran and the items are controlled for export from the United
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
45
States to Iran. Non-U.S. persons – including U.S.-owned or -controlled foreign entities –
also continue to be prohibited from reexporting from a third country items containing 10
percent or more U.S.-controlled content, if undertaken with knowledge or reason to know
that the reexportation is intended specifically for Iran or the Government of Iran.
However, the exportation or reexportation of U.S.-origin goods that are designated as
EAR99 from a third country to Iran without knowledge or reason to know at the time of
export from the United States that the goods are intended specifically for Iran is not
prohibited. Additional export controls administered by the Department of Commerce
may also apply. [01-16-2016]
K. 14. Does GL H authorize a U.S. person to alter its policies and procedures, or the
policies or procedures of its owned or controlled foreign entity, to allow the
U.S.-owned or -controlled foreign entity to establish a physical presence inside Iran?
Yes. GL H authorizes a U.S. parent to alter its policies and procedures, and/or the
policies and procedures of its owned or controlled foreign entity, to allow the U.S.-owned
or -controlled foreign entity to establish a physical presence inside Iran. U.S.-owned
or -controlled foreign entities, however, continue to be prohibited from the exportation,
reexportation, sale, or supply, directly or indirectly, from the United States of any goods,
technology, or services if the items are destined for Iran or the Government of Iran at the
time they leave the United States (see FAQs K.13 and M.9). [06-08-2016]
K. 15. Are U.S.-owned or -controlled foreign entities considered U.S. persons?
No. The term United States person or U.S. person, as it is defined in section 560.314 of
the ITSR, means any United States citizen, permanent resident alien, entity organized
under the laws of the United States or any jurisdiction within the United States (including
foreign branches), or any person in the United States. Although U.S.-owned
or -controlled entities are subject to the prohibitions of the ITSR pursuant to section
560.215 (and eligible for the authorizations of GL H), they are not considered U.S.
persons under the ITSR. [06-08-2016]
K. 16. Does GL H authorize U.S.-owned or -controlled foreign entities to engage in
transactions with individuals and entities on the E.O. 13599 list?
Yes. GL H authorizes U.S.-owned or -controlled foreign entities to engage in
transactions with individuals and entities on the E.O. 13599 List that are within the scope
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
46
of the general license (see FAQ I.2 for additional information on the E.O. 13599 List).
[06-08-2016]
K. 17. Does OFAC aggregate the interests of multiple U.S. persons in determining whether
an entity established or maintained outside the United States is a U.S.-owned
or -controlled foreign entity for purposes of GL H and section 560.215 of the ITSR?
Yes, with certain exceptions. As a general matter, an entity established or maintained
outside the United States is considered owned or controlled by a U.S. person if, in the
aggregate, one or more U.S. persons hold(s) a 50 percent or greater equity interest by
vote or value in the entity or if one or more U.S. persons hold(s) a majority of seats on
the board of directors of the entity. A determination as to whether one or more U.S.
persons otherwise control(s) the actions, policies, or personnel decisions of a foreign
entity is a fact-specific, case-by-case determination, but in making such a determination,
OFAC would look to the aggregated ownership interests held, and indicia of control
exercised, by all relevant U.S. persons.
In the specific case of companies organized under the laws of a country other than the
United States that are publicly traded or where ownership interests are otherwise widely
dispersed, OFAC would not regard such an entity to be owned or controlled by a U.S.
person if U.S. persons, in the aggregate, passively hold more than 50 percent of the
shares of such entity but no one U.S. person holds a controlling share in the company.
However, such a company could still be considered a U.S.-owned or -controlled foreign
entity to the extent one or more of the other criteria for ownership or control are met.
[06-08-2016]
K. 18. In cases where multiple U.S. persons, in the aggregate, own or control a foreign
entity, are U.S. persons authorized under GL H to amend the policies and
procedures of stakeholding U.S. companies and the policies and procedures of the
U.S.-owned or -controlled foreign entity?
Yes. In cases where U.S. persons, in the aggregate, own or control a foreign entity, U.S.
persons are permitted to amend the policies and procedures of U.S. entities that own a
portion of the U.S.-owned or -controlled foreign entity, as well as the policies and
procedures of the U.S.-owned or -controlled foreign entity, to the extent necessary to
allow the U.S.-owned or -controlled foreign entity to engage in transactions with Iran that
are authorized under GL H (see FAQ K.6 for additional details on the extent to which
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
47
U.S. persons can engage in altering policies and procedures related to transactions with
Iran). [06-08-2016]
K. 19. Does GL H authorize a U.S. person to establish or alter the operating policies and
procedures of a United States entity or a U.S.-owned or -controlled foreign entity
more than once?
Yes. A U.S. person can undertake additional changes to such operating policies and
procedures so long as the changes are not with respect to, or for the purpose of
facilitating, any particular transaction(s) involving Iran by the U.S.-owned or -controlled
foreign entity. [06-08-2016; updated on 10-07-2016]
K. 20. Must U.S. persons employed by or serving on the Board of Directors of a
U.S.-owned or -controlled foreign entity be recused or “walled off” from all Iranrelated
business of that entity? Can U.S. person employees simply abstain from
voting on Iran-related matters?
In general, unless authorized by OFAC, U.S. persons employed by or serving on the
board of directors of a U.S.-owned or -controlled foreign entity (or any other foreign
entity) must be recused or “walled off” from all Iran-related business of that entity,
except for certain limited activities with respect to Iran that are authorized under section
(a) of that GL (see FAQs K.8 and K.9).
U.S. persons are authorized under GL H to allow for such a recusal through the
establishment or alteration of policies and procedures of their owned or controlled foreign
entities. U.S.-owned or -controlled foreign entities (and other foreign entities) should
consider instituting a blanket recusal policy (as opposed to case-by-case abstentions,
which, depending on the facts and circumstances, could be considered a prohibited
facilitation and/or export of services under the ITSR) for U.S. person directors, managers,
and other employees with respect to Iran-related matters (see FAQ C.16). [06-08-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
48
K. 21. Must the U.S. parent company of a U.S.-owned or -controlled foreign entity
engaging in transactions with Iran pursuant to GL H remove itself from all day-today
operations of its owned or controlled foreign entity, or just those related to
Iran?
If a U.S. parent company’s owned or controlled foreign entity engages in transactions
with Iran pursuant to GL H, and also conducts transactions with other non-sanctioned
jurisdictions, the U.S. parent company and its board members, senior management, and
employees may continue to be involved in the U.S.-owned or -controlled foreign entity’s
day-to-day operations with non-sanctioned jurisdictions. [06-08-2016]
K. 22. Can a U.S. person receive reports from its owned or controlled foreign entities that
detail transactions conducted pursuant to GL H, including reporting on
transactions that the U.S. person is required to disclose to the Securities and
Exchange Commission?
Yes. A U.S. person may receive reports from its owned or controlled foreign entities that
include details on transactions the foreign entity conducted with Iran pursuant to GL H.
However, U.S. persons remain prohibited from engaging in Iran-related activities of
U.S.-owned or -controlled foreign entities and cannot attempt to influence Iran-related
business decisions of such entities based on such reports. [06-08-2016]
L. IMPORTS OF IRANIAN-ORIGIN CARPETS AND FOODSTUFFS
L. 1. Under the JCPOA, the United States committed to license, upon Implementation
Day, the importation into the United States of Iranian-origin carpets and foodstuffs,
including pistachios and caviar. What types of Iranian-origin carpets and
foodstuffs may be imported into the United States under the general license?
Pursuant to its commitment under the JCPOA, the United States is authorizing the
importation into the United States of Iranian-origin carpets and foodstuffs, including
pistachios and caviar. This general license, which is effective upon publication in the
Federal Register, covers: (1) carpets and other textile floor coverings and carpets used as
wall hangings that are classified under chapter 57 or heading 9706.00.0060 of the
Harmonized Tariff Schedule of the United States and (2) foodstuffs intended for human
consumption that are classified under chapters 2-23 of the Harmonized Tariff Schedule of
the United States. Carpets and foodstuffs imported pursuant to the general license will
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
49
still be subject to all other laws and regulations applicable to goods imported into the
United States, including generally applicable laws and regulations administered by other
U.S. departments and agencies, such as the Department of Agriculture, Department of
Commerce, the Food and Drug Administration, and the Department of Homeland
Security.
The following are examples of transactions that are permitted under the general license:
(1) A United States person living abroad is permitted to purchase or sell an Iranian-origin
carpet, as long as the sale is not to Iran, the Government of Iran, an Iranian financial
institution, or any other person whose property and interests in property are blocked
pursuant to section 560.211 of the ITSR.
(2) A United States person may process a documentary collection relating to the
importation into the United States of Iranian-origin pistachios, but payment under the
documentary collection may not involve the crediting of an Iranian account, as defined in
section 560.320 of the ITSR. [01-16-2016]
L. 2. How can U.S. persons pay Iranian companies for these imports?
Under the ITSR, U.S. depository institutions and registered brokers or dealers in
securities are authorized to process transfers of funds to or from Iran, or for the direct or
indirect benefit of persons in Iran or the Government of Iran, if the transfer arises from,
and is ordinarily incident and necessary to give effect to, an underlying transaction that
has been authorized by a general or specific license issued pursuant to, or set forth in, the
ITSR and does not involve crediting or debiting an Iranian account, as defined in section
560.320 of the ITSR (see section 560.516 of the ITSR). This payment mechanism is
available for transactions related to generally-licensed importations of Iranian-origin
carpets and foodstuffs. For additional information regarding this payment mechanism,
see FAQ 242.
In addition, subject to certain conditions, U.S. depository institutions are authorized
under the general license to process letters of credit for payments for Iranian-origin
carpets and foodstuffs, and U.S. persons are also authorized to act as brokers for the
purchase or sale of the categories of Iranian-origin carpets and foodstuffs covered by the
general license.
The following are examples of transactions that are permitted under the general license:
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
50
(1) A United States depository institution may issue a letter of credit in favor of an
exporter in Iran to finance the importation into the United States of Iranian-origin caviar;
the letter of credit may be confirmed by a third-country bank that is not included within
the definition of the term Government of Iran or an Iranian financial institution.
(2) A United States depository institution may advise or confirm a letter of credit issued
by a third-country bank that is not included within the definition of the term Government
of Iran or an Iranian financial institution to finance the purchase from a third country of
Iranian-origin carpets by a U.S. person or third-country national.
(3) A United States person may broker the sale of Iranian-origin carpets from Iran to a
third-country national located outside Iran or to another U.S. person wherever located.
(4) A bank that is owned or controlled by the Government of Iran may forward letter of
credit documents, strictly on a documentary collection basis, either directly to a United
States depository institution or to a third-country bank that is not included within the
definition of the term Government of Iran or an Iranian financial institution and that is
party to a letter of credit issued by a United States depository institution. The Iranian
bank may not, however, send the documents on an “approval” basis, since it is not and
cannot be party to the letter of credit. [01-16-2016]
M. OTHER
M. 1. Are Iranian citizens who are permanent residents of the United States or dual U.S.-
Iranian citizens located anywhere in the world generally permitted to conduct
business or trade with Iranian companies or operate a business in Iran?
No. Both an Iranian citizen who is a permanent resident alien of the United States and an
individual who is a dual U.S.-Iranian citizen meet the definition of a U.S. person set forth
in section 560.314 of the ITSR, regardless of where in the world they are located. U.S.
persons are generally prohibited under the ITSR from engaging in transactions or
dealings involving Iran that are not exempt from regulation or authorized by OFAC.
However, OFAC has issued a number of general licenses that authorize U.S. persons,
including Iranian citizens who are permanent residents of the United States and dual
U.S.-Iranian citizens located anywhere in the world, to conduct certain activities with
regard to Iran that would otherwise be prohibited under the ITSR, such as the exportation
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
51
to Iran of agricultural commodities (including food), medicine, and medical supplies and
the exportation of hardware, software, and services incident to personal communications.
The United States committed in the JCPOA to license certain activities involving U.S.
persons, including the sale to Iran of commercial passenger aircraft and related parts and
services, provided they are used exclusively for commercial passenger aviation; the
importation of Iranian-origin carpets and foodstuffs; and activities involving Iran
conducted by foreign subsidiaries of U.S. companies. [01-16-2016]
M. 2. What level of due diligence is expected from industry since there is no relief for the
IRGC in the JCPOA, given the IRGC plays a significant role in the Iranian
economy?
After Implementation Day, non-U.S. persons who knowingly conduct significant
financial transactions with Iranian or Iran-related persons on the SDN List, including the
IRGC, continue to be exposed to sanctions (see FAQ A.6).
OFAC recommends that a person considering business in Iran or with Iranian persons
conduct due diligence sufficient to ensure that it is not knowingly engaging in
transactions with the IRGC or other Iranian or Iran-related persons on the SDN List (see
FAQ A.6), and keep records documenting that due diligence. U.S. persons may refer to
FAQ 116 for additional guidance on compliance expectations for intermediary banks.
[01-16-2016]
M. 3. How will we know if sanctions snap back? How far in advance will we know that
sanctions are to snap back?
The United States is committed to ensuring the JCPOA’s success, and will make every
effort to resolve any concerns through the procedures established under the JCPOA. In
the event that we are unable to resolve our concerns through the established procedures,
the U.S. government would communicate this information clearly to the public via the
same channels used to communicate previous JPOA and JCPOA updates. We are unable
to predict how far in advance notice will be given in the event that sanctions snap back.
[01-16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
52
M. 4. In the event of a snapback, will sanctions apply retroactively to legitimate business
activity that takes place after Implementation Day but before the snapback occurs?
No. The United States has committed not to retroactively impose sanctions for legitimate
activity undertaken after Implementation Day. Transactions conducted after the
snapback occurs, however, could be sanctionable to the extent they implicate activity for
which sanctions have been re-imposed. The JCPOA does not grandfather contracts
signed prior to snapback. For more information regarding snapback, please see FAQ M.
5. [01-16-2016; updated on 12-15-2016]
M. 5. In the past the U.S. government has authorized a wind-down period when new
sanctions came into effect to allow companies to disengage from Iran. Will a winddown
period be provided in the event sanctions are re-imposed on Iran?
The U.S. government has a past practice of working with U.S. or third-country
companies to minimize the impact of sanctions on the legitimate activities of those
parties undertaken prior to the imposition of sanctions, and we anticipate doing the same
in the event of a JCPOA sanctions snapback.
As a general matter, in the event of a JCPOA sanctions snapback, the U.S. government
would provide non-U.S., non-Iranian persons a 180-day period to wind down operations
in or business involving Iran that was consistent with the U.S. sanctions lifting under the
JCPOA and undertaken pursuant to a written contract or written agreement entered into
prior to snapback.
In the event that a non-U.S., non-Iranian person is owed payment at the time of snapback
for goods or services fully provided or delivered to an Iranian counterparty prior to
snapback pursuant to a written contract or written agreement entered into prior to
snapback and such activities were consistent with U.S. sanctions in effect at the time of
delivery or provision, the U.S. government would allow the non-U.S., non-Iranian person
to receive payment for those goods or services according to the terms of the written
contract or written agreement. Similarly, if a non-U.S., non-Iranian person is owed
repayment for loans or credits extended to an Iranian counterparty prior to snapback
pursuant to a written contract or written agreement entered into prior to snapback and
such activities were consistent with U.S. sanctions in effect at the time the loans or
credits were extended, the U.S. government would allow the non-U.S., non-Iranian
person to receive repayment of the related debt or obligation according to the terms of the
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
53
written contract or written agreement. This allowance is designed for non-U.S., non-
Iranian parties to be made whole for debts and obligations owed or due to them for goods
or services fully provided or delivered or loans or credit extended to an Iranian party
prior to snapback. Any payments would need to be consistent with U.S. sanctions,
including that payments could not involve U.S. persons or the U.S. financial system,
unless the transactions are exempt from regulation or authorized by OFAC.
To the extent that snapback results in the revocation of general or specific licenses issued
by OFAC, the U.S. government would, consistent with the conditions described above,
provide U.S. persons and U.S.-owned or -controlled foreign entities a 180-day period to
wind down operations in or business involving Iran conducted pursuant to an OFAC
authorization, and to receive payments according to the terms of the written contract or
written agreement entered into prior to snapback for goods or services fully provided or
delivered pursuant to an OFAC authorization prior to snapback.
With the exception of goods or services necessary to wind down operations in or business
involving Iran during the 180-day period, the provision or delivery of additional goods or
services and/or the extension of additional loans or credits to an Iranian counterparty after
snapback, including pursuant to written contracts or written agreements entered into prior
to snapback, may result in the imposition of U.S. sanctions unless such activities are
exempt from regulation, authorized by OFAC, or not otherwise sanctionable.
The U.S. government would evaluate matters falling outside the above parameters on a
case-by-case basis.
If U.S. sanctions were to snap back in whole or in part, OFAC would provide additional
guidance in this regard on its website. [01-16-2016; updated on 12-15-2016]
M. 6. The Main Text of the JCPOA, paragraph 30, states that “Following the lifting of
sanctions under this JCPOA as specified in Annex II, ongoing investigations on
possible infringements of such sanctions may be reviewed in accordance with
applicable national laws.” What does this mean with respect to any investigations
into or enforcement of U.S. sanctions violations?
As a general matter, the nuclear-related sanctions that are the subject of U.S.
commitments in Annex II of the JCPOA are secondary sanctions that are directed toward
the activity of non-U.S. persons occurring outside of the United States that is not
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
54
otherwise subject to U.S. jurisdiction. To the extent an ongoing investigation of a non-
U.S. person relates to activity within the scope of the secondary sanctions to be lifted on
Implementation Day, the U.S. government will not sanction the non-U.S. person under
those authorities following Implementation Day.
Notwithstanding the JCPOA, the U.S. government will continue to administer and
enforce a range of sanctions with respect to Iran, including the domestic trade embargo
implemented through the ITSR. The ITSR largely prohibit U.S. persons from exporting,
directly or indirectly, goods, technology, and services to, or importing goods, technology,
and services from, Iran. Under longstanding practice, apparent sanctions violations are
analyzed in light of the laws and regulations that were in place at the time of the
underlying activities, and civil and criminal enforcement authorities are applied
accordingly. Investigations into apparent violations of U.S. sanctions authorities that
were not lifted on Implementation Day, including the ITSR, will not be affected by the
JCPOA, and future enforcement actions may follow. Similarly, investigations into
apparent violations resulting from pre-Implementation Day activities that would be
within the scope of authorizations available beginning on Implementation Day will not be
affected by the JCPOA, and future enforcement actions may follow. [01-16-2016]
M. 7. Do the U.S. commitments with respect to sanctions contained in the JCPOA alter or
impact any prior enforcement actions OFAC has taken with respect to any entity,
including non-U.S. financial institutions?
No. None of the enforcement actions that OFAC has finalized to date, including any
settlement agreement or the terms and conditions set forth therein, will be altered or
impacted in any way by implementation of the JCPOA. To the extent that any party,
including a non-U.S. financial institution, has entered into a settlement agreement with
OFAC, the party will continue to be bound by that agreement after Implementation Day.
[01-16-2016]
M. 8. Do the U.S. commitments with respect to sanctions contained in the JCPOA alter or
impact any prior enforcement actions by regulatory authorities other than OFAC?
OFAC does not expect the JCPOA to alter or impact any prior enforcement actions by
other regulatory authorities. Specific questions regarding the potential impact of the
JCPOA on enforcement actions taken by other agencies, such as settlement agreements,
consent orders, or cease and desist orders agreed to or issued by federal, state, and/or
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
55
local banking regulators, or deferred prosecution agreements that violators have entered
into with the U.S. Department of Justice and/or state or local law enforcement agencies,
should be directed to the relevant regulatory or enforcement agency. [01-16-2016]
M. 9. After Implementation Day, are U.S. persons able to export, reexport, sell, or
provide goods, services, or technology to Iran? And can non-U.S. persons export,
reexport, sell, or provide U.S. goods, services, or technology to Iran?
No, unless the transaction is exempt from regulation or authorized by OFAC. Under
section 560.204 of the ITSR, U.S. persons continue to be broadly prohibited from
exporting any goods, services, or technology directly or indirectly to Iran, with the
exception of transactions that are exempt from regulation or authorized by OFAC.
Furthermore, section 560.204 of the ITSR generally prohibits the exportation,
reexportation, sale, or supply, directly or indirectly, of any goods, technology, or services
from the United States or by U.S. persons to a person in a third country undertaken with
knowledge or reason to know that such goods, technology, or services are intended
specifically for supply, transshipment, or reexportation, directly or indirectly, to Iran or
the Government of Iran; or that such goods, technology, or services are intended
specifically for use in the production of, for commingling with, or for incorporation into
goods, technology, or services to be directly or indirectly supplied, transshipped, or
reexported exclusively or predominantly to Iran or the Government of Iran. These
prohibitions remain in place even if secondary sanctions on the transaction or activity
have been lifted under the JCPOA.
In addition, pursuant to section 560.205 of the ITSR, non-U.S. persons continue to be
prohibited from reexporting from a third country, directly or indirectly, any goods,
technology, or services that have been exported from the United States if they know or
have reason to know that the reexportation is intended specifically for Iran or the
Government of Iran and the items are controlled for export from the United States to Iran.
Non-U.S. persons also continue to be prohibited from reexporting from a third country
items containing 10 percent or more U.S.-controlled content, if undertaken with
knowledge or reason to know that the reexportation is intended specifically for Iran or the
Government of Iran. However, the exportation or reexportation of U.S.-origin goods that
are designated as EAR99 under the EAR from a third country to Iran without knowledge
or reason to know at the time of export from the United States that the goods are intended
specifically for Iran would not be prohibited. Additional export controls administered by
the Department of Commerce may also apply. [01-16-2016]
Annex 150
This document remains available on OFAC’s website only to assist persons in determining
which activities were consistent with the JCPOA sanctions lifting, as in effect from January 16,
2016 through May 8, 2018. Please note that the Departments of State and of the Treasury
have issued additional guidance regarding activities that may be undertaken during the winddown
periods. To the extent there are discrepancies between this document and guidance
issued by the Department of State or the Department of the Treasury on or after May 8,
2018, the later-issued guidance should be treated as governing.
Issued on January 16, 2016
Last Updated on December 15, 2016
56
M. 10. Is it sanctionable for non-U.S. persons to engage in transactions with an entity that
is not on the SDN List, but that is minority owned, or that is controlled in whole or
in part, by an Iranian or Iran-related person on the SDN List?
It is not necessarily sanctionable for a non-U.S. person to engage in transactions with an
entity that is not on the SDN List but that is minority owned, or that is controlled in
whole or in part, by an Iranian or Iran-related person on the SDN List. However, OFAC
recommends exercising caution when engaging in transactions with such entities to
ensure that such transactions do not involve Iranian or Iran-related persons on the SDN
List (see FAQ A.6). [10-07-2016]
M. 11. For non-U.S. persons conducting due diligence on a potential Iranian counterparty,
does OFAC consider only checking the SDN List to be sufficient due diligence?
Screening the names of Iranian counterparties against the SDN List is a step that would
generally be expected, but that is not necessarily sufficient (see FAQ A.6). In addition to
checking the SDN List, non-U.S. persons should consult with their local regulators
regarding due diligence expectations in their domestic jurisdictions. In particular, the
non-U.S. person should ensure that its due diligence procedures conform to its internal
risk-assessment and overall compliance policies, which – in addition to other business
considerations – should be based on best practices of the particular industry at issue and
conform to guidance and expectations of the non-U.S. person’s home country regulators.
OFAC suggests maintaining records documenting those due diligence efforts (see FAQ
M.2). [10-07-2016]
M. 12. Does OFAC expect non-U.S. financial institutions to conduct due diligence on their
customer’s Iranian customers?
OFAC considers the appropriate level of due diligence to depend on the financial
institution’s role in a transaction (see FAQ 116). While OFAC would consider it a best
practice for a non-U.S. financial institution to perform due diligence on its own
customers, OFAC does not expect a non-U.S. financial institution to repeat the due
diligence its customers have performed on an Iranian customer unless the non-U.S.
financial institution has reason to believe that those processes are insufficient. Non-U.S.
financial institutions should consult with their local regulators regarding due diligence
expectations in their domestic jurisdictions. [10-07-2016]
Annex 150
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 1/50
U.S. DEPARTMENT OF THE TREASURY
OFAC FAQ Index General Questions Sanctions
Compliance
Sanctions Lists
and Files
Iran Sanctions Other Sanctions
Programs
Resource Center
OFAC FAQs: Iran Sanctions
Search OFAC FAQs Using Treasury Recommendations:
Example: Where is OFAC's Country List? Search
Skip to the Following Topics:
Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA)
Treasury CISADA Findings Against Bank of Kunlun
Executive Order 13599 (Blocking Property of the Government of Iran and Iranian Financial Institutions)
NDAA (Section 1245 of the National Defense Authorization Act for Fiscal Year 2012)
Executive Order 13606 (the GHRAVITY E.O.)
Foreign Sanctions Evaders (FSE) Executive Order (Prohibiting Certain Transactions with and Suspending Entry into the United States of Foreign Sanctions
Evaders with Respect to Iran and Syria)
Executive Order 13622, "Authorizing Additional Sanctions With Respect to Iran"
Determination Pursuant to Section 312 of the Iran Threat Reduction and Syria Human Rights Act
Section 4 of Executive Order "Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012
and Additional Sanctions with Respect to Iran"
Iranian Transactions and Sanctions Regulations and the Statement of Licensing Procedure on Support Of Human Rights-, Humanitarian-, and Democracy-
Related Activities With Respect to Iran
Implementation of Section 504 of the Iran Threat Reduction and Syria Human Rights Act of 2012
Iran Freedom and Counter-Proliferation Act of 2012 (IFCA)
General Licenses (GL) for Agricultural Commodities, Medicine, and Medical Devices in the Iranian Transactions and Sanctions Regulations
Extension of Temporary Sanctions Relief to Implement the Joint Plan of Action between the P5 + 1 and the Islamic Republic of Iran
Iranian General License with Respect to Certain Services, Software, and Hardware Incident to Personal Communications (Iranian General License D-1)
Payments or the Facilitation of Payments to Iranian Civil Aviation Authorities for Overflights of Iran or Emergency Landing in Iran
Joint Comprehensive Plan of Action “Adoption Day”
Provision of Routine Goods and Services by non-U.S. persons to Diplomatic Missions of the Government of Iran
The Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA) on Implementation Day
Additional Iran-related Questions From Financial Institutions
Amendments to General Licenses for the Exportation or Reexportation of Agricultural Commodities, Medicine, and Medical Devices to Iran
Amendment to the Definition of "Iranian-origin goods" or "goods of Iranian origin" in the Iranian Transactions and Sanctions Regulations
Countering America’s Adversaries Through Sanctions Act (CAATSA) Section 105
Guidance Related to Humanitarian Assistance with Regard to the November 12, 2017 Earthquake in Iran
Frequently Asked Questions Regarding Executive Order 13846 of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran”
Frequently Asked Questions Regarding Executive Order “Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran” of May 8,
2019
CISADA (Comprehensive Iran Sanctions, Accountability, and Divestment Act
of 2010)
Print this topic
149. What activities by foreign financial institutions can subject them to CISADA sanctions?
As described in the Iranian Financial Sanctions Regulations, the sanctionable activities of a foreign financial institution are:
Facilitating the efforts of the Government of Iran (GOI) to acquire or develop Weapons of Mass Destruction (WMD) or
delivery systems for WMD or to provide support for terrorist organizations or acts of international terrorism;
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 2/50
Facilitating the activities of a person subject to financial sanctions pursuant to UNSCRs 1737 , 1747 , 1803 , or
1929 , or any other Security Council resolution that imposes sanctions with respect to Iran;
Engaging in money laundering, or facilitating efforts by the Central Bank of Iran or any other Iranian financial institution, to
carry out either of the facilitating activities described above; or
Facilitating a significant transaction or transactions or providing significant financial services for: (i) the Islamic
Revolutionary Guard Corps or any of its agents or affiliates whose property and interests in property are blocked pursuant
to the International Emergency Economic Powers Act (IEEPA), or (ii) a financial institution whose property and
interests in property are blocked pursuant to IEEPA in connection with Iran’s proliferation of WMD, Iran’s proliferation of
delivery systems for WMD, or Iran’s support for international terrorism.
150. Where can I find a list of Islamic Revolutionary Guard Corps (IRGC) affiliates and Iran-linked financial institutions
“blocked pursuant to the International Emergency Economic Powers Act (IEEPA)”?
The list of blocked IRGC affiliates and blocked Iran-linked financial institutions is dynamic and is based on the identity of
“designated” persons, which refers both to natural persons (i.e., individuals) and legal persons (such as corporations and other
entities). The most recent list of designated persons – which includes most, but not all, blocked entities* – can be found at
www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx. The listings of designated IRGC entities will be
followed by the tag [IRGC]; those of designated Iran-linked financial institutions will have the tag [IFSR].
*Under Department of the Treasury regulations, designated persons are those that are named on the list. All interests in
property of such persons are blocked, and such persons are considered to have an interest in all property and entities in which
they own, directly or indirectly, a 50 percent or greater interest. As a result, such property and entities are also blocked, even if
they do not themselves appear on the list.
151. How do the Iranian Financial Sanctions Regulations (IFSR) define “U.S. financial institutions”?
The Iranian Financial Sanctions Regulations (IFSR) define “U.S. financial institutions” to include: depository institutions, banks,
savings banks, money service businesses, trust companies, insurance companies, securities brokers and dealers,
commodities exchanges, clearing corporations, investment companies, employee benefit plans, and U.S. holding companies,
U.S. affiliates, or U.S. subsidiaries of any of these entities. Covered institutions include those branches, offices, and agencies
of foreign financial institutions that are located in the United States.
152. How do the Iranian Financial Sanctions Regulations (IFSR) define “foreign financial institutions”?
The Iranian Financial Sanctions Regulations (IFSR) define “foreign financial institutions” to include foreign depository
institutions, banks, savings banks, money service businesses, trust companies, securities brokers and dealers, commodities
exchanges, clearing corporations, investment companies, employee benefit plans, and holding companies, affiliates, or
subsidiaries of any of these entities.
153. How do the Iranian Financial Sanctions Regulations (IFSR) define the term “knowingly”?
The term “knowingly” as used in the IFSR means that a person has actual knowledge or should have known of specific
conduct, a circumstance, or a result. In other words, the IFSR could be implicated if the Treasury Department finds that a
foreign financial institution knew or should have known that it engaged in one or more of the sanctionable activities.
154. How does the Treasury Department determine whether a transaction or financial service is “significant” for
purposes of the Iranian Financial Sanctions Regulations (IFSR)?
As set out in the IFSR, in determining whether a transaction or financial service is “significant,” the Treasury Department may
consider: (1) the size, number, frequency, and nature of the transaction(s); (2) the level of awareness of management of the
transaction(s) and whether or not the transaction(s) are a part of a pattern of conduct; (3) the nexus between the foreign
financial institution involved in the transaction(s) and a blocked Islamic Revolutionary Guard Corps individual or entity or
blocked Iran-linked financial institution; (4) the impact of the transaction(s) on the goals of the Comprehensive Iran Sanctions,
Accountability, and Divestment Act (CISADA) ; (5) whether the transaction(s) involved any deceptive practices; and (6)
other factors the Treasury Department deems relevant on a case-by-case basis.
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 3/50
155. When are the prohibitions and strict conditions on foreign financial institutions’ correspondent accounts or
payable-through accounts in the United States effective?
A finding by the Treasury Department that a foreign financial institution knowingly engages in one or more of the sanctionable
activities is necessary before the Treasury Department can prohibit or impose strict conditions on the opening or maintaining in
the United States of correspondent accounts or payable-through accounts for that foreign financial institution.
156. How will U.S. and foreign financial institutions know that the Treasury Department has made such a finding?
As a general matter, the Treasury Department will reach out to foreign financial institutions to inquire about their conduct before
making a finding. If the Treasury Department decides to impose strict condition(s), the Treasury Department will issue an order
or a regulation that sets out the strict condition(s) to be imposed on the U.S. correspondent accounts or U.S. payable-through
accounts of the relevant foreign financial institution and publish the order or regulation in the Federal Register. The Federal
Register is available at www.gpo.gov/fdsys/. If the Treasury Department decides to prohibit the opening or maintaining of U.S.
correspondent accounts or U.S. payable-through accounts for a foreign financial institution, the Treasury Department will add
the name of the foreign financial institution and publish it to the part 561 list .
157. How will the Treasury Department enforce the Iranian Financial Sanctions Regulations (IFSR) with respect to U.S.
entities?
Any U.S. person who violates the correspondent account provisions of the IFSR may be subject to civil penalties of up to the
greater of $250,000 or twice the transaction value, and criminal penalties for willful violations of up to $1 million and 20 years in
prison. A U.S. financial institution may be subject to civil penalties of up to the greater of $250,000 or twice the transaction
value, if any person that it owns or controls violates the IFSR prohibition on engaging in any transaction with or benefitting the
Islamic Revolutionary Guard Corps (IRGC) or any of its agents or affiliates whose property and interests in property are
blocked pursuant to the International Emergency Economic Powers Act (IEEPA), and if the U.S. financial institution knew or
should have known that the person violated the IFSR.
158. Can the application of any part(s) of the Iranian Financial Sanctions Regulations (IFSR) be waived by the
Department of the Treasury?
The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) provides for a waiver of the sanctions
under the Iranian Financial Sanctions Regulations (IFSR) if the Secretary of the Treasury determines that a waiver is
necessary to the national interest of the United States.
159. Where can I find the text of the Iranian Financial Sanctions Regulations?
The text of the Iranian Financial Sanctions Regulations (IFSR) can be found at: www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/ fr75_49836.pdf.
Executive Order 13599 (Blocking Property of the Government of Iran and
Iranian Financial Institutions)
Print this topic
On February 5, 2012, the President signed Executive Order 13599 to implement section 1245(c) of the National Defense
Authorization Act for Fiscal Year 2012, Public Law 112-81 (“NDAA ”) and to take additional steps with respect to Iran.
Effective as of 12:01 a.m. eastern standard time on February 6, 2012, the order blocks all property and interests in property of
the Government of Iran (including the Central Bank of Iran), all Iranian financial institutions, and all persons determined by the
Secretary of the Treasury, in consultation with the Secretary of State, to be owned or controlled by, or to have acted or
purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked
pursuant to the order. [02-06-2012]
160. Section 1 of E.O. 13599 blocks all property and interests in property of the Government of Iran, including the
Central Bank of Iran, and of all Iranian financial institutions, that are in the United States, that come within the United
States, or that come within the possession or control of U.S. persons (including overseas branches). Can you provide
further clarification about this provision of E.O. 13599?
E.O. 13599 requires U.S. persons to block (i.e., freeze) all property and interests in property of the Government of Iran,
including the Central Bank of Iran, and of all Iranian financial institutions, which also includes the Central Bank of Iran. This
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 4/50
means that all individuals and entities that meet the definition of “Government of Iran” (“GOI”) as defined by section 7(d) of the
new E.O. as well as all Iranian financial institutions (whether or not they meet the definition of the GOI) are now blocked.
Previously, under the Iranian Transactions Regulations, 31 C.F.R. part 560 (the “ITR”), financial institutions and other U.S.
persons were prohibited from engaging in transactions with the GOI. Under those prior rules, U.S. financial institutions
receiving instructions to execute transactions involving these entities were not required to block the transactions, but were
instead required to reject those instructions rather than carry them out, unless the transactions were exempt, authorized, or not
prohibited by OFAC. The Executive Order defines an “Iranian financial institution” as a financial institution organized under the
laws of Iran or any jurisdiction within Iran (including foreign branches), any financial institution in Iran, any financial institution,
wherever located, owned or controlled by the Government of Iran, and any financial institution, wherever located, owned or
controlled by any of the aforementioned entities.
As a result, transactions involving entities bearing the [IRAN] tag on OFAC’s List of Specially Designated Nationals and
Blocked Persons (“SDN List”) will now need to be blocked unless exempt or authorized by OFAC. Going forward, the [IRAN]
tag will connote that a person or entity meets the definition of the term “GOI” or “Iranian Financial Institution”. OFAC will
continue to update the SDN List and may add, delete, or edit entries as appropriate.
E.O. 13599 blocks the property and interests in property of any individual or entity that comes within its definition of the term
“Government of Iran” regardless of whether it is listed on the SDN List, and similarly it blocks the property and interests in
property of all Iranian financial institutions as defined in the order regardless of whether the Iranian financial institution is listed
on the SDN List.
E.O. 13599 builds upon the prohibitions in the ITR, which remain in effect.
Please note, pursuant to OFAC guidance, even when an entity does not itself appear on the SDN List or otherwise meet the
definition of the GOI or an Iranian financial institution, the property and interests in property of that entity are blocked if the
entity is owned, directly or indirectly, 50% or more by a person whose property and interests in property are blocked pursuant
to an Executive Order or regulations administered by OFAC. [02-06-2012]
161. If all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all
Iranian financial institutions are blocked, can I conduct transactions involving the Government of Iran that have been
previously authorized by OFAC?
Generally yes. Under new General License A, almost all transactions that are authorized under existing general licenses
issued pursuant to the Iranian Transactions Regulations (ITR) or under existing OFAC specific licenses will continue to be
authorized under the authority of E.O. 13599 . However, transactions previously authorized under one existing ITR general
license are not authorized pursuant to E.O. 13599. Specifically, the closing of accounts of the Government of Iran or an Iranian
financial institution and the lump sum transfer of the balances to an account outside of the United States, which is authorized
by sections 560.517(a)(3) & (b)(2) of the ITR, is not authorized by General License A, and, therefore, those transactions are
prohibited by E.O. 13599 and the accounts must be blocked. In addition, General License A does not authorize any payments
from blocked funds or debits to blocked accounts, with a limited exception for payments from funds or debits to accounts
blocked under the Iranian Assets Control Regulations (the hostage crisis blocking program that began in 1979) that are
authorized by specific licenses issued by OFAC.
New General License B authorizes U.S. depository institutions and U.S. registered brokers or dealers in securities to process
noncommercial, personal remittances, to or from Iran, or for or on behalf of individuals ordinarily resident in Iran who are not
included in the term “Government of Iran”, provided that such funds transactions are not made by, to, or through a financial
institution blocked pursuant to the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 C.F.R. part 544 (the
“WMDPSR”), or the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (the “GTSR”), or a person whose property and
interests in property are blocked pursuant to any other part of 31 C.F.R. chapter V, or any Executive order, except an Iranian
financial institution whose property and interests in property are blocked solely pursuant to E.O. 13599.
Transactions not previously authorized by OFAC that involve property or interests in property of the Government of Iran,
including the Central Bank of Iran, or of Iranian financial institutions must be blocked. [02-06-2012]
162. Are U.S. persons still required to comply with the Iranian Transactions Regulations (ITR)?
Yes. E.O. 13599 builds upon the prohibitions of the ITR, and the prohibitions of the ITR remain in effect. [02-06-2012]
163. What are the differences and similarities between E.O. 13599 and the Iranian Transactions Regulations (ITR)?
The ITRprohibit prohibit virtually all direct or indirect transactions involving Iran or the Government of Iran by U.S. persons or
with a nexus to the United States, unless otherwise authorized by OFAC or exempted by statute, but they do not contain
blocking provisions. E.O. 13599 requires U.S. persons to block all property and interests in property of the Government of
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 5/50
Iran, including the Central Bank of Iran, and of Iranian financial institutions, which also includes the Central Bank of Iran, unless
it relates to a transaction that is exempted by statute or authorized by OFAC.
To illustrate the difference between how a transaction would be treated under the ITR and the new E.O., imagine a commercial
wire transfer being processed through the U.S. financial system by order of a third-country, non-U.S. company for credit to a
third-country financial institution in favor of a correspondent account it maintains for an Iranian financial institution. The
transaction is not exempt or authorized by a general or specific license, and the Iranian bank is not blocked pursuant to the
GTSR or the WMDPSR. Previously, under the ITR, any U.S. financial institution handling the transaction would have needed to
reject the payment because allowing it to be processed would constitute a prohibited exportation of services to Iran. With the
new E.O. in place, the U.S. financial institution would be required to block (“freeze”) that transaction. [02-06-2012]
164. The Iranian Transactions Regulations (ITR) authorize U.S. depository institutions and U.S. registered brokers or
dealers in securities to process transfers of funds to or from Iran if the transfer is a non-commercial, personal
remittance. Are U.S. depository institutions and U.S. registered brokers or dealers in securities still authorized to
process such payments to or from a Government of Iran-owned bank that is not otherwise designated pursuant to
another part of 31 C.F.R. Chapter V?
General License B under E.O. 13599 authorizes U.S. depository institutions and U.S. registered brokers or dealers in
securities to process noncommercial, personal remittances to or from Iran provided that the payment is not made by, to, or
through a financial institution designated by OFAC under the WMDPSR, or the GTSR, or a person whose property and
interests in property are blocked pursuant to any other part of 31 C.F.R. chapter V, or any Executive order, except an Iranian
financial institution whose property and interests in property are blocked solely pursuant to E.O. 13599. Exempt or authorized
transactions to or from Iran may also be processed subject to the above conditions.
Such transactions must be processed through a third country, as U.S. banks are prohibited from operating correspondent
accounts for Iranian banks. The transactions may involve the use of blocked Iranian financial institutions as long as the Iranian
financial institution is blocked solely pursuant to E.O. 13599 (and not pursuant to any other Executive order or part of 31 C.F.R.
chapter V) and there is a third-country, non-U.S. financial institution as an intermediary between the U.S. financial institution
and the Iranian financial institution. [02-06-2012]
165. To what extent are U.S. persons expected to conduct enhanced due diligence to determine if transactions contain
a Government of Iran interest?
E.O. 13599 requires U.S. persons to block all property and interests in property of the Government of Iran, unless otherwise
exempt or authorized by OFAC.
Please contact the OFAC Hotline at 202-622-2490 or 1-800-540-6322, or by email at [email protected], for
guidance regarding entities that you suspect are owned or controlled by the Government of Iran that do not appear on the SDN
List. As a general matter, OFAC expects financial institutions to conduct due diligence on their own direct customers (including,
for example, their ownership structure) to confirm that those customers are not persons whose property and interests in
property are blocked.
With regard to other types of transactions where a financial institution is acting solely as an intermediary and fails to block
transactions involving a sanctions target, OFAC will consider the totality of the circumstances surrounding the bank’s
processing of the transaction to determine what, if any, regulatory response is appropriate. [02-06-2012]
166. OFAC’s SDN List contains a list of entities identified by OFAC as being the Government of Iran. Should U.S.
persons now block the property and interests in property of those entities?
Yes, U.S. persons should now block the property and interests in property of the Government of Iran entities appearing on the
SDN List, unless OFAC has authorized the underlying transaction or the transaction is exempt. [02-06-2012]
167. OFAC has granted my company a license under the Trade Sanctions Reform and Export Enhancement Act of
2000 (“TSRA”) and the Iranian Transactions Regulations (ITR). Can I continue to conduct the licensed transaction?
Under General License A issued pursuant to E.O. 13599 , transactions authorized under existing specific licenses issued
pursuant to TSRA and the ITR are authorized under E.O. 13599 until the specific license expires, per the terms of the license.
[02-06-2012]
168. OFAC has issued me a (non-TSRA) specific license related to Iran, or the Government of Iran. Can I continue to
conduct the licensed transactions?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 6/50
Under General License A issued pursuant to E.O. 13599 , transactions authorized by (non-TSRA) specific licenses issued
prior to the issuance of E.O. 13599 and issued pursuant to any part of 31 C.F.R. chapter V are also authorized under E.O.
13599. As set forth in General License A, in most cases these new authorizations under E.O. 13599 are in effect until
theexpiration date of the individual specific license, or, if the specific license has no expiration date, until April 6, 2012. [02-06-
2012]
NDAA (Section 1245 of the National Defense Authorization Act for Fiscal Year
2012)
Print this topic
On December 31, 2011, the President signed into law the National Defense Authorization Act for Fiscal Year 2012, Public Law
112-81 (“NDAA ”). Section 1245 of this statute requires the President to block the property and interests in property subject
to U.S. jurisdiction of all Iranian financial institutions, including the Central Bank of Iran (“CBI”). It also aims to reduce Iranian oil
revenues and discourage transactions with the CBI by providing for sanctions on foreign financial institutions that knowingly
conduct or facilitate certain significant financial transactions with the CBI. Although the sanctions on foreign financial
institutions authorized by section 1245 are similar to the financial sanctions under the Comprehensive Iran Sanctions,
Accountability, and Divestment Act of 2010 (22 U.S.C. 8513(c)) (“CISADA”) (i.e., prohibiting and/or imposing strict
conditions on opening or maintaining correspondent accounts or payable-through accounts in the United States), there are
differences in the scope and operation of the two statutes. [02-14-2012]
169. What is the NDAA?
On December 31, 2011, the President signed into law the National Defense Authorization Act (NDAA ). Section 1245 of the
NDAA requires the President to block the property and interests in property subject to U.S. jurisdiction of all Iranian financial
institutions, including the Central Bank of Iran (CBI). It also aims to reduce Iranian oil revenues and discourage transactions
with the CBI by providing for sanctions on foreign financial institutions that knowingly conduct or facilitate certain significant
financial transactions with the CBI. [02-14-2012]
170. What activities can trigger sanctions on a foreign financial institution under the NDAA?
For private financial institutions, the Act mandates that the President sanction those institutions that are found to knowingly
conduct or facilitate any significant transactions with a U.S.-designated Iranian financial institution or with the Central Bank of
Iran (CBI) – whether for the purchase of petroleum or otherwise – unless the transaction is for the sale of food, medicine, or
medical devices to Iran. For all transactions with the CBI other than petroleum purchases, this provision takes effect on
February 29, 2012, i.e., 60 days after the enactment of the Act. The timing of the petroleum purchase sanctions is discussed
immediately below.
Private financial institutions and all other foreign financial institutions – including central banks or foreign state-owned or -
controlled banks – potentially face sanctions under the NDAA if they knowingly conduct or facilitate significant financial
transactions for the purchase of Iranian petroleum or petroleum products with a U.S.-designated Iranian financial institution or
with the CBI after the provision takes effect as early as June 28, 2012, i.e., 180 days after enactment.* This NDAA provision
may be held in abeyance beyond June 28, 2012, depending on the President’s determination on the availability and price of
alternative supplies. Foreign central and foreign state-owned or -controlled banks are also subject to these sanctions if the
transactions are for the sale of petroleum or petroleum products to Iran and they occur after June 28, 2012.
All foreign financial institutions, including private and state-owned institutions, remain subject to section 104(c) of the
Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), which calls for sanctions on foreign financial
institutions that are found to have knowingly engaged in facilitating significant transactions for specific Iranian-linked individuals
and entities. [02-14-2012]
*Irrespective of the timeframes set forth in the NDAA, any foreign financial institution that knowingly facilitates significant
transactions with any U.S.-designated Iranian financial institution would still be subject to CISADA.
171. Does the NDAA (National Defense Authorization Act) repeal or amend Section 104(c) of CISADA (the
Comprehensive Iran Sanctions, Accountability, and Divestment Act)?
No. Any foreign financial institution that knowingly facilitates significant transactions or provides significant financial services for
a U.S.-designated, Iranian-linked financial institution can be sanctioned under section 104(c) of CISADA and section
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 7/50
561.201 of the Iranian Financial Sanctions Regulations (“IFSR”) even if those transactions are not sanctionable under section
1245(d) of the NDAA . Though the NDAA imposes sanctions on foreign financial institutions similar to financial sanctions
under CISADA and the IFSR (i.e., prohibiting and/or imposing strict conditions on opening or maintaining correspondent
accounts or payable-through accounts in the United States), there are differences in the scope and operation of the statutes.
[02-14-2012]
172. How does Executive Order 13599, “Blocking Property of the Government of Iran and Iranian Financial
Institutions,” and the blocking of all Iranian financial institutions affect the financial sanctions provisions in CISADA?
Do CISADA sanctions now apply to financial transactions with any Iranian financial institution?
The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) applies to transactions with only those
Iranian financial institutions that are designated in connection with Iran’s WMD or terrorism activities and are denoted on
OFAC’s List of Specially Designated Nationals and Blocked Persons (the SDN list) with the [IFSR] tag. While E.O. 13599
does block the property of all Iranian financial institutions, that action is not grounded in the authorities that relate to
counterproliferation or counterterrorism, and therefore does not implicate CISADA. [02-14-2012]
173. Are there any exceptions to the sanctions provisions in the National Defense Authorization Act (NDAA)?
Yes. The NDAA includes an exception that prohibits the President from imposing sanctions “with respect to any person for
conducting or facilitating a transaction for the sale of food, medicine, or medical devices to Iran.” [02-14-2012]
174. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “owned or
controlled by the government of a foreign country,” “food, medicine, and medical devices,” “foreign financial
institution,” “Iranian financial institution,” “significantly reduced,” and “whether the price and supply of petroleum
and petroleum products produced in countries other than Iran is sufficient”?
“significant financial transaction”
The Iranian Financial Sanctions Regulations (IFSR), which implement section 104(c) of the Comprehensive Iran Sanctions,
Accountability, and Divestment Act (CISADA), identify factors to be used in determining what is significant (as it relates to
transactions) in 31 C.F.R § 561.404, which allows the Secretary of the Treasury to consider the “totality of the facts and
circumstances” while providing a list of seven broad factors that can play a role in the determination, including: (1) the size,
number, and frequency of transactions; (2) the nature of the transaction(s); (3) the level of awareness of management and
whether the transaction(s) are part of a pattern of conduct; (4) the nexus between the transaction(s) and a blocked person; (5)
the impact of the transaction(s) on statutory objectives; (6) whether the transaction(s) involve deceptive practices; and (7) such
other factors that the Secretary deems relevant on a case-by-case basis. Treasury anticipates closely modeling the definition of
“significant” for National Defense Authorization Act (NDAA ) purposes on the IFSR.
We anticipate utilizing a broad definition of “financial transaction” that encompasses “any transfer of value involving a financial
institution.” The term “transaction” includes, but is not limited to, the following:
The holding of nostro, vostro, or loro accounts for or with the Central Bank of Iran or designated banks, such as Bank
Melli Iran and/or Bank Saderat Iran, including any of their branches or subsidiaries worldwide (collectively the “Listed
Parties”);
The provision of trade finance and/or letter of credit services for or with Listed Parties;
The provision of guarantees or similar instruments for or with Listed Parties;
The provision of investment products or instruments for Listed Parties and/or the participation with Listed Parties in
investments;
The receipt or origination of wire transfers on behalf of or involving Listed Parties;
The acceptance of commercial paper (both retail and wholesale) drawn on Listed Parties, and the clearance of such
paper (including, but not limited to, checks and similar drafts);
The receipt or origination of ACH or ATM transactions with Listed Parties; and/or
Any other transactions for or on behalf of, directly or indirectly, Listed Parties and/or with Listed Parties serving as
correspondents, respondents, or beneficiaries. That would include transactions where the Listed Parties do not appear on
the face of the transaction but where the transaction is undertaken with knowledge of the involvement of a Listed Party
based on a relationship that exists through a third party such as a money exchange or trading house.
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 8/50
“knowingly”
The IFSR defines “knowingly” with respect to conduct, a circumstance, or a result, to mean that an entity or individual had
actual knowledge, or should have known, about the conduct, the circumstance, or the result. 31 C.F.R. § 561.314. Treasury
anticipates closely modeling the definition of this term on the IFSR.
“owned or controlled by the government of a foreign country”
The Iranian Transactions Regulations (“ITR”) define “an entity owned or controlled by the Government of Iran” in section
560.313. Borrowing from that definition, a financial institution “owned or controlled by the government of a foreign country”
would be deemed to include a financial institution in which a foreign government owns a 50% or greater interest or which is
otherwise controlled by a foreign government. Treasury anticipates closely modeling the definition of this term under the
NDAA on the ITR definition.
“food, medicine, and medical devices”
“Food”: The October 2011 general license for the ITR and the Sudanese Sanctions Regulations (“SSR”) authorizing certain
food exports to Iran and Sudan defines “food” as “items that are intended to be consumed by and provide nutrition to humans
or animals in Iran – including vitamins and minerals, food additives and supplements, and bottled drinking water – and seeds
that germinate into items that are intended to be consumed by and provide nutrition to humans or animals in Iran.” The
regulations also specify that food does not include alcoholic beverages, cigarettes, gum, or fertilizer. Treasury anticipates
closely modeling the definition of this term under the NDAA on this license definition.
“Medicine”: ITR section 560.530(e)(2) states that: “For the purposes of this part, the term medicine has the same meaning
given the term ‘drug’ in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321) but does not include any item
listed on the Commerce Control List in the Export Administration Regulations, 15 CFR part 774, supplement no. 1 (excluding
items classified as EAR 99).” Similarly, under the Trade Sanctions Reform and Export Act (“TSRA”), 22 U.S.C. 7201(5), “[t]he
term ‘medicine’ has the meaning given the term "drug" in section 321 of title 21.” Treasury anticipates closely modeling the
definition of this term under the NDAA on the ITR and TSRA.
“Medical Devices”: ITR section 560.530(e)(3) states that: “For the purposes of this part, the term medical device has the
meaning given the term ‘device’ in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. § 321) but does not
include any item listed on the Commerce Control List in the Export Administration Regulations, 15 CFR part 774, supplement
no. 1 (excluding items classified as EAR 99).” Similarly, under TSRA, 22 U.S.C. 7201(4), “[t]he term "medical device" has the
meaning given the term ‘device’ in section 321 of title 21.” Treasury anticipates closely modeling the definition of this term
under the NDAA on the ITR and TSRA.
“foreign financial institution”
“Foreign financial institution” is defined in section 1245 of the NDAA with reference to section 104(i) of CISADA (22 U.S.C.
§ 8513(i)). As further defined in the IFSR, a “foreign financial institution” is “any foreign entity that is engaged in the business of
accepting deposits, making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign
exchange, securities, commodity futures or options, or procuring purchasers and sellers thereof, as principal or agent. It
includes but is not limited to depository institutions, banks, savings banks, money service businesses, trust companies,
securities brokers and dealers, commodity futures and options brokers and dealers, forward contract and foreign exchange
merchants, securities and commodities exchanges, clearing corporations, investment companies, employee benefit plans, and
holding companies, affiliates, or subsidiaries of any of the foregoing.” 31 C.F.R. § 561.308. It does not include “the international
financial institutions identified in 22 U.S.C. 262r(c)(2), the International Fund for Agricultural Development, or the North
American Development Bank.” 31 C.F.R. § 561.308. Treasury anticipates closely modeling the definition of this term under the
NDAA on the IFSR.
“Iranian financial institution”
This term is defined in E.O. 13599 as: “a financial institution organized under the laws of Iran or any jurisdiction within Iran
(including foreign branches), any financial institution in Iran, any financial institution, wherever located, owned or controlled by
the Government of Iran, and any financial institution, wherever located, owned or controlled by any of the foregoing.” Such
financial institutions include, but are not limited to, any foreign entity that is engaged in the business of accepting deposits,
making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, or
commodity futures or options, or procuring purchasers and sellers thereof, as principal or agent. It includes but is not limited to
depository institutions, banks, savings banks, money service businesses, trust companies, insurance companies, securities
brokers and dealers, commodity futures and options brokers and dealers, forward contract and foreign exchange merchants,
securities and commodities exchanges, clearing corporations, investment companies, employee benefit plans, and holding
companies, affiliates, or subsidiaries of any of the foregoing.
“significantly reduced”
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 9/50
The Secretary of State, in consultation with the Secretary of the Treasury, the Secretary of Energy, and the Director of National
Intelligence, will make determinations as to whether any country has significantly reduced the volume of Iranian crude oil
purchases. Any determinations will be preceded by a process of rigorous due diligence. The Secretary of State intends to
consider relevant evidence in assessing each country’s efforts to reduce the volume of crude oil imported from Iran, including
the quantity and percentage of the reduction in purchases of Iranian crude oil over the relevant period, termination of contracts
for future delivery of Iranian crude oil, and other actions that demonstrate a commitment to substantially decrease such
purchases.
“whether the price and supply of petroleum and petroleum products produced in countries other than Iran is
sufficient”
The President will make a determination, based on the reports required by subparagraph (A) of Section 1245(d)(4) of the
NDAA , as to whether the price and supply of petroleum and petroleum products produced in countries other than Iran is
sufficient to permit purchasers of petroleum and petroleum products from Iran to reduce significantly in volume their purchases
from Iran. [02-14-2012]
175. What is the scope of “petroleum products” under the law?
As defined by the U.S. Energy Information Administration (EIA), petroleum products include unfinished oils, liquefied petroleum
gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel
oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas,
and miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other
hydrocarbon compounds. In keeping with the EIA’s standard definition, petroleum products do not include natural gas, liquefied
natural gas, biofuels, methanol, and other non-petroleum fuels. [02-14-2012]
176. If oil is being provided as payment for an outstanding debt, is such a transfer considered a “financial
transaction”?
If a transfer involves a financial institution it would likely be considered a financial transaction. [02-14-2012]
177. If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise
acting solely as an intermediary in a transaction between a non-designated Iranian bank and a foreign financial
institution, is the foreign financial institution deemed to be engaging in a transaction with the CBI?
Section 1245 targets any significant transactions “with” the CBI; a transaction involving the CBI in an intermediary role would
likely be viewed as a transaction “with” the CBI. [02-14-2012]
178. Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section
1245?
If a transfer involves a financial institution it would likely be considered a financial transaction. [02-14-2012]
179. Does the definition of “significant financial transaction” exclude the passive holding of Central Bank of Iran (CBI)
reserves? Is the U.S. willing to give assurances that this will not be a basis for sanctions?
This will be a case-by-case determination and will require specifics on what “passive holding” entails. As a general matter, we
would likely not view the holding of reserves as sanctionable in the following circumstances: the accounts are frozen or
restricted, under which the CBI would be allowed to maintain accounts that it had already opened as of December 31, 2011,
but would otherwise be unable to direct the disposition of those funds, with ordinary commercial interest payments and routine
roll-overs of time deposits under pre-existing instructions being the only new transactions. [02-14-2012]
180. Are payments made under contracts existing prior to the date of enactment of the National Defense Authorization
Act (NDAA) statute (December 31, 2011) exempted from the definition of “significant transactions”?
No general exception will be provided for payments arising out of pre-existing contracts. The assessment of whether such
payments are “significant” will be done on a case-by-case basis in line with the criteria discussed in FAQ #174. [02-14-2012]
181. Will the U.S. refrain from sanctioning foreign financial institutions that receive funds from the Central Bank of
Iran (CBI) to repay loans? What if these loans were granted for projects that might be subject to the food, medicine,
and medical device exemptions under the National Defense Authorization Act (NDAA)?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 10/50
As noted, no general exception will be provided for payments arising out of pre-existing contracts. The assessment of whether
such payments are “significant” will be done on a case-by-case basis in line with the criteria discussed in FAQ #174. Regarding
payments for food, medicine, and medical devices, the NDAA does not allow sanctions based on transactions for the sale
of food, medicine, or medical devices to Iran. Payments related to the export of broader humanitarian items would be dealt with
in our analysis of what constitutes a “significant financial transaction” and would be considered on a case-by-case basis. [02-
14-2012]
182. Is there a difference between entities that have been designated by the United States Government for illicit
conduct, such as proliferation of weapons of mass destruction or support for terrorism, and those that are being
blocked under E.O. 13599? How can I tell which entities appear on the Specially Designated National (SDN) List for
which reasons?
Both blocked and designated entities appear on the SDN List.
“Blocked” persons, in the context of E.O. 13599 , appear on the SDN List due to the United States Government’s
identification of these entities as the Government of Iran and/or as an Iranian financial institution. Such entities are identified on
the SDN List with the tag [IRAN]. For example, Bank Keshavarzi is a Government of Iran owned Iranian financial institution and
is identified with the [IRAN] tag. Additionally, the National Iranian Oil Company (NIOC) is a non-financial institution that has
been identified as the Government of Iran and bears the [IRAN] tag.
“Designated” persons appear on the SDN List due to the United States Government’s having determined that they meet the
criteria set forth in any of a number of other Executive Orders concerning, for example, assisting Iran’s weapons of mass
destruction development, or aiding international terrorism and designating them for such activities. Such entities are identified
on the SDN List with various tags other than [IRAN], such as [NPWMD] or [SDGT]. For example, Islamic Republic of Iran
Shipping Lines is listed as: “IRISL [NPWMD].”
Note that many entries on the SDN List have more than one tag. For example: Bank Saderat Iran has three tags: [SDGT],
indicating that it has been sanctioned for providing services to terrorism; [IRAN], indicating that it is the Government of Iran;
and [IFSR], referring to the Iranian Financial Sanctions Regulations to signal to third country financial institutions that engage
with entities with this tag that they risk sanctions under CISADA. [02-14-2012]
Executive Order 13606 (the GHRAVITY E.O.)
Print this topic
On April 22, 2012, the President signed Executive Order 13606 Blocking The Property And Suspending Entry into the
United States of Certain Persons with Respect to Grave Human Rights Abuses by the Governments of Iran and Syria Via
Information Technology (the “GHRAVITY E.O.”). Effective 12:01 a.m. eastern daylight time on April 23, 2012, the GHRAVITY
E.O. blocks all property and interests in property of persons listed in its Annex, and all persons determined by the Secretary of
the Treasury, in consultation with or at the recommendation of the Secretary of State, to meet the criteria in the order. [04-23-
2012]
183. Why did the President issue the GHRAVITY E.O.?
The GHRAVITY E.O. follows prior Executive orders issued by the President in response to the commission of human rights
abuses by the Governments of Iran and Syria. With the GHRAVITY E.O., the President recognized that the commission of
serious human rights abuses against the people of Iran and Syria by their governments, facilitated by computer and network
disruption, monitoring, and tracking by those governments, threatens the national security and foreign policy of the United
States. The GHRAVITY E.O. targets this activity in order to deter and disrupt such abuses. [04-23-2012]
184. What does the GHRAVITY E.O. do?
The GHRAVITY E.O. blocks (i.e., freezes) the property and interests in property of, among others, any person determined
by the Secretary of the Treasury, in consultation with or at the recommendation of the Secretary of State, (1) to have operated,
or to have directed the operation of, information and communications technology that facilitates computer or network
disruption, monitoring, or tracking that could assist in or enable serious human rights abuses by or on behalf of the
Government of Iran or the Government of Syria; or (2) to have sold, leased, or otherwise provided, directly or indirectly, goods,
services, or technology to Iran or Syria likely to be used to facilitate such activities.
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 11/50
U.S. persons in possession of property or interests in property belonging to persons listed in the Annex to the GHRAVITY E.O.,
or designated in the future by Treasury under the E.O., are obligated to block the property and report the blocking to OFAC
within 10 days of blocking. Entities that are 50% or more owned by persons blocked by the GHRAVITY E.O. are also blocked,
regardless of whether such entities appear on the Annex or OFAC’s list of Specially Designated Nationals and Blocked
Persons (“SDN list”). [04-23-2012]
185. What type of activities does the GHRAVITY E.O. target?
The GHRAVITY E.O. targets the provision and use of information and communications technology to facilitate computer or
network disruption, monitoring, or tracking that could assist in or enable serious human rights abuses by or on behalf of the
Government of Iran or the Government of Syria. It is not intended to block exports of technology that enable the Syrian and
Iranian people to freely communicate among themselves and with the outside world.
“Information and communications technology” means any hardware, software, or other product or service primarily intended to
fulfill or enable the function of information processing and communication by electronic means, including transmission and
display, including via the Internet. [04-23-2012]
186. How do I know that a person has been designated under the GHRAVITY E.O.?
Persons designated under the GHRAVITY E.O. appear on the publicly available Specially Designated Nationals List (SDN
list) bearing the [HRIT] tag. U.S. persons are obligated to block property involving the persons bearing the tag [HRIT] on the
SDN list, unless the transaction is exempt or otherwise authorized by OFAC. [04-23-2012]
187. Does the GHRAVITY E.O. prohibit me from exporting technology to companies that do business with Iran or
Syria?
This E.O. does not generally prohibit transactions involving persons that do business with Iran or Syria, unless the person has
been designated pursuant to this order. You should consult with the Department of Commerce’s Bureau of Industry and
Security (BIS) regarding exports to companies that do business with Syria. [04-23-2012]
188. If I am a non-U.S. company that exports information and communications technology to Iran or Syria, will I be
designated under the GHRAVITY E.O.?
The measures in this order are designed primarily to address the need to prevent entities located in whole or in part in Iran and
Syria from facilitating or committing serious human rights abuses. These measures are not designed to prevent the provision of
information and communications technology necessary to enable the Iranian and Syrian people to freely communicate with
each other and the outside world. That said, those providing communications technology to Iran or Syria that has the potential
to facilitate computer or network disruption, monitoring, or tracking should exercise great caution given Iran and Syria’s use of
this technology to assist in the commission of serious human rights abuses. [04-23-2012]
189. Would I need authorization from OFAC or BIS if I wanted to export goods or technology to persons blocked under
the GHRAVITY E.O.?
Yes. For more information regarding exports of goods or technology to persons blocked under the GHRAVITY E.O. please
contact OFAC or BIS. [04-23-2012]
190. Are existing licenses issued by the U.S. Government involving persons designated under the GHRAVITY E.O. still
valid?
U.S. persons who have been issued licenses involving persons designated under the GHRAVITY E.O. should check with
the issuing agency regarding the validity of their licenses. [04-23-2012]
FSE Executive Order (Prohibiting Certain Transactions with and Suspending
Entry into the United States of Foreign Sanctions Evaders with Respect to Iran
and Syria)
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 12/50
Print this topic
191. What does Executive Order 13608 “Prohibiting Certain Transactions with and Suspending Entry into the United
States of Foreign Sanctions Evaders with Respect to Iran and Syria” do?
This Executive Order gives Treasury new authorities. First, it strengthens Treasury’s ability to address behavior by foreign
individuals and entities determined to have violated, attempted to violate, conspired to violate, or caused a violation of U.S.
sanctions on Syria or Iran. This E.O. also gives Treasury the authority to impose sanctions on foreign persons who have
facilitated deceptive transactions for or on behalf of persons subject to U.S. sanctions.
Transactions by U.S. persons or within the United States involving persons sanctioned under this authority are prohibited,
effectively cutting the listed persons off from the U.S. marketplace and financial system. By cutting off access to the U.S.
marketplace and financial system to such sanctions evaders, Executive Order 13608 provides Treasury with a powerful tool to
prevent and deter such behavior and to hold such persons accountable and to convince them to change their behavior. Publicly
identifying such persons will also allow U.S. persons to avoid unwittingly engaging in transactions with identified foreign
persons that may expose U.S. persons to the risk of sanctions violations. [05-01-2012]
192. Why was this authority needed?
Executive Order 13608 expands Treasury’s ability to address the behavior of foreign persons determined to have violated
or attempted to violate U.S. sanctions on Syria or Iran, or to have facilitated deceptive transactions on behalf of persons
subject to those sanctions, where the foreign person had no physical, financial, or other presence in the United States and did
not submit to U.S. administrative proceedings. Treasury may use this authority where it appears that a foreign person violated
U.S. sanctions on Iran or Syria but may not meet criteria for designation under existing Executive Orders. Executive Order
13608 will provide a means through which Treasury can limit the risk to U.S. commercial and financial systems posed by
foreign persons determined to have violated U.S. sanctions on Iran or Syria, or to have engaged in deceptive transactions for
or on behalf of persons subject to U.S. sanctions on Iran or Syria.
Such a listing under Executive Order 13608 also provides Treasury with the capability to put the world on notice as to such
foreign persons’ activity and the risk of similar future activity. Such identification will help prevent U.S. persons from unwittingly
engaging in transactions with foreign persons that may pose a risk of sanctions violations. [05-01-2012]
193. What are the repercussions of an individual or entity being identified under Executive Order 13608?
If an individual or entity is made subject to sanctions under this authority, U.S. persons generally may no longer provide to or
procure from such individual or entity any goods, services, or technology. From a practical standpoint, it means that the
sanctioned individual or entity will be cut off from the U.S. commercial and financial systems. [05-01-2012]
194. Are U.S. persons required to block the property of individuals and entities identified under Executive Order
13608?
No. Identifications or listings under Executive Order 13608 do not block any assets. However, a U.S. person may not
provide or procure goods or services, including financial services, or technology to or from a listed person without authorization
from OFAC, unless the transaction is otherwise exempt from regulation under the International Emergency Economic Powers
Act (e.g., certain travel-related transactions). [05-01-2012]
336. How do I know whether a person is identified under E.O. 13608?
Please refer to the Foreign Sanctions Evaders (FSE) List. [02-06-2014]
195. I am a financial institution. What do I do if I receive a wire transfer involving a listed party?
A U.S. financial institution must reject any wire transfer involving a listed person and file a report with OFAC within 10 days.
[05-01-2012]
196. I am a financial institution and I hold an account for a listed person. What do I do with the funds?
The account is not blocked; however, it is restricted and you cannot allow it to be operated without authorization from OFAC.
[05-01-2012]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 13/50
197. What are U.S. persons obligated to do with property of a person listed under Executive Order 13608?
Property of a listed person is not blocked, but U.S. persons must have authorization from OFAC to provide or procure such
property to or from a listed person, or to provide or procure services to or from a listed person in connection with such property.
Additionally, wire transfers involving the assets of an Executive Order 13608-listed person must be rejected. [05-01-2012]
198. May a U.S. person deal with an Executive Order 13608-listed person so long as the dealing does not involve Iran
or Syria?
No. U.S. persons are prohibited from all transactions or dealings described in Executive Order 13608 with persons listed
under Executive Order 13608, unless authorized by OFAC or where the transaction is otherwise exempt from regulation under
the International Emergency Economic Powers Act . [05-01-2012]
199. How is an identification or listing under Executive Order 13608 different from a designation?
Like a designation, a U.S. person is prohibited, unless authorized by OFAC or if the underlying transaction is exempt from
regulation under the International Emergency Economic Powers Act , from dealing with an identified or listed person. Unlike
a blocking designation, the property and the interests in property of a person listed under Executive Order 13608 are not
blocked. [05-01-2012]
200. How is this different from lists maintained by the Department of Commerce?
Treasury’s authority under Executive Order 13608 has some similarities to Commerce’s authority under the Export
Administration Regulations (“EAR”). Commerce may impose denial orders on persons (both foreign and U.S.) who have
committed violations of the EAR or present an imminent risk of committing a violation. These individuals or organizations are
listed on Commerce’s Denied Persons List. It is prohibited to deal with Denied Persons in any export transaction involving
items (commodities, software, and technology) subject to the EAR. Treasury’s authority under Executive Order 13608
complements Commerce’s authority by addressing at least two types of sanctions violations that are outside the scope of the
EAR. Specifically, Treasury may prohibit the provision of services (in addition to goods and technology) to or from identified or
listed persons and Treasury may prohibit transactions or dealings involving goods and technology that are not subject to the
EAR. However, unlike Commerce’s authority, Treasury’s authority to sanction or list an individual or entity under Executive
Order 13608 may be implemented only with respect to foreign individuals or entities. [05-01-2012]
201. May a U.S. person deal with a person listed under Executive Order 13608 in a transaction that was previously
licensed by OFAC?
No. U.S. persons cannot have any dealings with a person identified or listed under this Executive Order absent specific
authorization from OFAC pursuant to the Executive Order 13608 , unless the transaction is exempt from regulation under
the International Emergency Economic Powers Act . [05-01-2012]
202. What if the transaction is already underway?
If a transaction is underway at the time of a listing, a U.S. person must cease dealing with the listed person and the U.S.
person is prohibited from engaging in transactions or dealings in or related to any goods, services, or technology to or from the
listed person, unless the transaction is exempt under the International Emergency Economic Powers Act , or until such time
that OFAC authorizes the transactions pursuant to the Executive Order 13608 . Additionally, if the transaction underway
involves a wire transfer, a U.S. financial institution must reject it and file a report with OFAC within 10 days.
Like all of its programs, OFAC has the authority under Executive Order 13608 to license transactions that are consistent with
U.S. foreign policy. [05-01-2012]
203. Can a U.S. person use a listed person to facilitate personal remittances to or from Iran or Syria?
No. Without specific authorization from OFAC, U.S. persons cannot use a listed person to process personal remittances. [05-
01-2012]
204. Will Treasury pursue an enforcement action before identifying or listing a person pursuant to Executive Order
13608?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 14/50
The authorities granted under this Executive Order are in addition to current authorities that Treasury has to pursue an
enforcement action for violations of U.S. law, and Treasury is not required to pursue a civil enforcement action prior to
identifying or listing a person pursuant to Executive Order 13608. [05-01-2012]
Treasury CISADA Findings Against Bank of Kunlun
Print this topic
207. What were the criteria for this finding? How many other institutions were you looking at and why did you decide
to take action against Bank of Kunlun?
Based on information made available to the Treasury Department, the Department has found that China’s Bank of Kunlun has
knowingly facilitated significant transactions for various Iranian-linked banks designated by the United States under our WMD
or terrorism authorities.
Upon finding that Bank of Kunlun was knowingly engaged in these activities that are sanctionable under the Comprehensive
Iran Sanctions, Accountability, and Divestment Act (CISADA), the Secretary of the Treasury has prohibited U.S. banks
from opening or maintaining correspondent accounts or payable-through accounts in the United States for Bank of Kunlun –
effectively cutting off Bank of Kunlun’s direct access to the U.S. financial system.
Since CISADA was signed into law in July 2010, Treasury has engaged with over 120 financial institutions and bank regulators
in more than 60 countries all over the world to brief them on the financial provisions of CISADA, and, in cases where we had
specific concerns, has shared information about those concerns.
This global engagement campaign has proven highly successful, as we have seen the overwhelming majority of financial
institutions with which we have engaged change their business practices – even close any correspondent accounts with U.S.
designated Iranian banks – to ensure that their access to the U.S. financial system is not put at risk.
The July 31, 2012 action against Bank of Kunlun was in response to its ongoing relationships with U.S.-designated Iranian
banks.
Note: The Treasury Department had also made a CISADA finding against Iraq’s Elaf Islamic Bank on July 31, 2012. On May
17, 2013, Elaf Islamic Bank was delisted and its name was removed from the Part 561 List . [05-17-2013]
208. How are you defining “significant” transactions and financial services?
In determining whether transactions or financial services are significant, the Secretary of the Treasury may consider a number
of factors related to the transactions or services, including, but not limited to: size, number, and frequency; type, complexity and
commercial purpose; the level of awareness or involvement by the bank’s management; whether the activity or payment
illustrates a pattern of practice or is an isolated event; the ultimate economic benefit conferred upon the designated person(s);
and whether the transactions involved the use of deceptive financial practices to obscure the identities of the parties involved.
Bank of Kunlun
Bank of Kunlun has provided hundreds of millions of dollars’ worth of services to U.S. designated Iranian banks. These
financial services include maintaining accounts, transferring payments, and serving as the paying bank for letters of credit
opened by U.S. designated Iranian banks. The facilitation of hundreds of millions of U.S. dollars worth of transactions with U.S.
designated Iranian banks over the past year is significant.
In 2012, after Treasury designated Bank Tejarat, Bank of Kunlun transferred hundreds of payments totaling approximately $100
million dollars for accounts it holds for Bank Tejarat and made a payment for an IRGC affiliate pursuant to a letter of credit
opened by Bank Tejarat. [05-17-2013]
209. What happens to the correspondent and payable-through accounts held by Bank of Kunlun in the United States?
To our knowledge, Bank of Kunlun does not currently hold correspondent accountswith U.S. financial institutions.
The July 31, 2012 action prohibits financial institutions in the United States from opening or maintaining correspondent or
payable-through accountsfor Bank of Kunlun. [05-17-2013]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 15/50
210. What are the consequences for a U.S. financial institution that maintains or opens a new correspondent or
payable-through account for Bank of Kunlun?
A U.S. financial institution that maintains or opens a correspondent or payable-through account for Bank of Kunlun is subject
to civil penalties in the amount of up to $250,000 or twice the value of the transaction, whichever is greater.
Criminal penalties of up to $1 million can be imposed for willful violations, and individuals who willfully violate the prohibition
can face up to 20 years in prison. [05-17-2013]
211. If a foreign financial institution continues to do business with Bank of Kunlun, could that lead to a CISADA
finding against the other institution?
Any foreign financial institution that knowingly facilitates significant transactionson behalf of designated Iranian banks –
whether directly or indirectly – may face Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA)
sanctions. OFAC defines “knowingly” in this context as meaning the financial institution knew or should have known of the
conduct, circumstance, or result. Bank of Kunlun has demonstrated its willingness to move hundreds of millions dollars on
behalf of designated Iranian banks. Accordingly, we would expect heightened due diligence in any dealings with Bank of
Kunlun. [05-17-2013]
212. Does this finding affect Bank of Kunlun’s branches or subsidiaries around the world? Does this finding affect any
holding companies?
The prohibitions implemented as a result of today’s action apply to Bank of Kunlun and all of its offices, around the world. [05-
17-2013]
213. Are United States financial institutions that do not hold correspondent or payable-through accounts for Bank of
Kunlun required to block or reject transactions that otherwise involve Bank of Kunlun?
No. U.S. financial institutions are not required to block or reject financial or trade transactions that involve Bank of Kunlun.
That said, we would expect heightened due diligence in any dealings with Bank of Kunlun given its demonstrated willingness to
facilitate transactions on behalf of Iranian banks designated by well over a dozen countries worldwide. [05-17-2013]
214. What is the licensing process for U.S. financial institutions that need to conduct transactions in order to close
correspondent or payable-through accounts with a foreign financial institution sanctioned pursuant to the
Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA)?
Treasury regulations provide a 10-day period in which U.S. financial institutions are authorized to engage in the transactions
necessary to close an affected account. If a U.S. financial institution that is in the process of closing an affected account seeks
to engage in transactions beyond those already authorized, Treasury may issue specific licenses on a case-by-case basis. [05-
17-2013]
215. What is the difference, in practical effect, between this and a designation under one of your other authorities, like
E.O. 13382?
The July 31, 2012 Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) finding prohibits the
opening or maintaining of correspondent accounts or payable-through accountsin the United States for Bank of Kunlun. This
action does not require the immediate freezing of any assets that Bank of Kunlun may hold within U.S. jurisdiction. [05-17-
2013]
Executive Order 13622 of July 30, 2012, “Authorizing Additional Sanctions
With Respect to Iran”
Print this topic
E.O. 13622 was revoked by E.O. 13716 of January 16, 2016. Please be advised that certain provisions of E.O. 13622 have
been incorporated into E.O. 13846 of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran”. FAQs relating
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 16/50
to E.O. 13846 can be found here. FAQs relating to E.O. 13622 have been archived and can be found here. [08-06-2018] [08-
06-2018]
Determination Pursuant to Section 312 of the Iran Threat Reduction and Syria
Human Rights Act (TER)
Print this topic
Section 312 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA) requires the Secretary of the
Treasury, no later than 45 days after the date of the enactment of TRA, to determine whether the National Iranian Oil Company
(NIOC) or the National Iranian Tanker Company (NITC) is an agent or affiliate of Iran’s Islamic Revolutionary Guard Corps
(IRGC), and to report to Congress on these determinations and the reasons for them. On September 24, 2012, the Department
of the Treasury made a determination that NIOC is an agent or affiliate of the IRGC. Based on the information currently
available, Treasury is not able to determine at this time whether NITC is an agent or affiliate of the IRGC.
233. Isn’t the National Iranian Oil Company (NIOC) already subject to sanctions?
Yes. Executive Order 13622 provides for sanctions on foreign financial institutions found to have knowingly conducted or
facilitated significant financial transactions with NIOC (except for sales of refined petroleum products to NIOC that fall below the
dollar threshold that could trigger sanctions under the Iran Sanctions Act ). Executive Order 13622 also provides authority
for the Secretary of the Treasury to block the property and interests in property of persons determined to have materially
assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC (as
well as other specified entities). Note, however, that these sanctions are not applicable to certain transactions related to the
Shah Deniz pipeline project, in which NIOC has a minority stake, under Executive Order 13622. In addition, NIOC was already
blocked as an entity of the Government of Iran under E.O. 13599 , which was issued pursuant to the International
Emergency Economic Powers Act (IEEPA), as amended, among other authorities. Nevertheless, as described below, the
determination that NIOC is an agent or affiliate of the IRGC carries consequences.
234. What is the effect of the National Iranian Oil Company (NIOC) determination? Are there CISADA implications?
As a result of this the Iran Threat Reduction and Syria Human Rights Act (TRA) section 312 determination, NIOC now is
also a person described under section 104(c)(2)(E)(i) of the Comprehensive Iran Sanctions, Accountability, and Divestment
Act of 2010 (CISADA) as an agent or affiliate of the IRGC whose property or interests in property are blocked pursuant to
IEEPA . This means that foreign financial institutions determined to knowingly facilitate significant transactions or provide
significant financial services for NIOC are exposed to CISADA sanctions, including prohibitions or the imposition of strict
conditions on the opening or maintaining of correspondent or payable-through accounts in the United States.
In addition, section 302 of TRA requires sanctions on foreign persons determined to have knowingly provided certain material
support to, or engaged in significant transactions with, the IRGC or its officials, agents, or affiliates whose property or interest in
property are blocked. Consequently, foreign persons that knowingly engage in significant transactions with NIOC after the
September 24, 2012 determination could be exposed to sanctions.
An “IRGC” identifier will be added to NIOC’s entry on the Specially Designated Nationals and Blocked Persons List available on
OFAC’s website.
As noted below, the potential application of sanctions under section 104(c)(2)(E)(i) of CISADA and section 302 of TRA is
affected by whether the country with primary jurisdiction has received a significant reduction exception from the Secretary of
State.
235. What are the implications for petroleum purchase transactions involving NIOC by financial institutions and
entities in countries that have received a significant reduction exception from the Secretary of State?
Significant transactions, financial services, or material support involving National Iranian Oil Company (NIOC) for the purchase
of Iranian petroleum or petroleum products by a foreign financial institution or entity based in a country that has received a
significant reduction exception from the Secretary of State do not carry potential sanctions consequences – under the
Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), sections 302 and 312 of the Iran Threat
Reduction and Syria Human Rights Act (TRA), section 1245 of the National Defense Authorization Act for Fiscal Year
2012 (NDAA), or sections 1 and 2 of Executive Order 13622 . Sections 302 and 312 of TRA authorize the President not
to impose sanctions for the purchase of petroleum or petroleum products from Iran if an exception under subsection 1245(d)(4)
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 17/50
(D) of the NDAA applies to the country with primary jurisdiction over the foreign financial institution at the time of the
transactions or the provision of services. Notwithstanding the foregoing, any significant transaction for other sanctioned entities
(such as Iranian designated banks or other persons described in section 104(c)(2)(E) of CISADA) may result in sanctions,
regardless of whether the transaction is for the purchase of petroleum or petroleum products and involves NIOC.
236. Does the determination regarding the National Iranian Tanker Company (NITC) mean that there is no affiliation
between NITC and the IRGC?
This statement means only that, based on the currently available information, Treasury is not able to determine at this time that
NITC is an agent or affiliate of the IRGC.
237. How does the effect of this determination compare to the effect of section 1(a) of Executive Order 13622 as to
transactions with National Iranian Oil Company (NIOC)?
The effect of the determination is similar to the effect of Executive Order 13622 section 1(a), which provides for prohibitions
on the opening of and prohibitions or strict conditions on maintaining correspondent accounts or payable-through accounts in
the United States for foreign financial institutions determined by the Secretary of the Treasury, in consultation with the
Secretary of State, to have knowingly conducted or facilitated significant financial transactions with NIOC. Executive Order
13622 likewise contains an exception that covers transactions with NIOC conducted or facilitated by foreign financial
institutions based in NDAA-excepted jurisdictions. A significant difference between these authorities is that the National
Defense Authorization Act (NDAA) exception in the Iran Threat Reduction and Syria Human Rights Act (TRA) section
312 is limited to transactions or financial services for the purchase of petroleum or petroleum products from Iran.
Section 4 of Executive Order 13628 of October 9, 2012, "Authorizing the
Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction
and Syria Human Rights Act of 2012 and Additional Sanctions with Respect to
Iran"
Print this topic
E.O. 13628 was amended by E.O. 13716 of January 16, 2016 and revoked by E.O. 13846 of August 6, 2018, “Reimposing
Certain Sanctions With Respect to Iran”. Please be advised that section 8 of E.O. 13846 continues in effect the sanctions
previously contained in section 4 of E.O. 13628 and expands them to cover activity sanctionable under E.O 13846. FAQs
relating to E.O. 13846 can be found here. FAQs relating to Section 4 of E.O. 13628 have been archived and can be found
here. [08-06-2018]
Iranian Transactions and Sanctions Regulations and the Statement of
Licensing Procedure on Support Of Human Rights-, Humanitarian-, and
Democracy-Related Activities With Respect to Iran
Print this topic
The Office of Foreign Assets Control ("OFAC") issued a final rule in the Federal Register on October 22, 2012, changing the
heading of the Iranian Transactions Regulations, 31 C.F.R. part 560 (the "ITR"), to the Iranian Transactions and Sanctions
Regulations, 31 C.F.R. part 560 (the "ITSR"), and amending the renamed ITSR to implement Executive Order ("E.O.")
13599 (other than section 11) and sections 1245(c) and (d)(1)(B) of the National Defense Authorization Act for Fiscal Year
2012 (the "NDAA"). These new regulations implement the blocking of the Government of Iran and all Iranian financial
institutions pursuant to E.O. 13599 and the NDAA.
OFAC is adding numerous new sections to the ITSR, including prohibitions, definitions, interpretations, and licensing
provisions. OFAC also is revising many existing sections of the ITSR in order to take account of the new government-wide
blocking as well as the blocking of all Iranian financial institutions. Due to the extensive nature of these and other amendments
described below, OFAC is reissuing the ITSR in their entirety.
In addition, OFAC is publishing on the Iran section of its Web site a Statement of Licensing Procedure on Support of Human
Rights-, Humanitarian-, and Democracy-Related Activities with Respect to Iran. The Statement of Licensing Procedure reflects
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 18/50
procedures established pursuant to the Iran Threat Reduction and Syria Human Rights Act of 2012 (the "TRA"), which was
signed into law by the President on August 10, 2012.
241. What are the major changes that the Iranian Transaction and Sanctions Regulations (ITSR) implement in
superseding the Iranian Transaction Regulations (ITR)?
The ITSR block the property and interests in property of the Government of Iran and all Iranian financial institutions that come
within the possession or control of any U.S. person, including any foreign branch, and prohibit all U.S. persons from dealing
with any property interests whatsoever, present, future, or contingent, of persons identified as already blocked pursuant to E.O.
13599 and the National Defense Authorization Act (NDAA).
OFAC is adding section 560.211 to the ITSR to implement the blocking prohibitions set forth in E.O. 13599 and the NDAA. New
sections 560.212 through 560.214 are being added to set forth certain consequences and requirements that stem from the
blocking prohibitions, including, inter alia, the requirement to hold blocked funds in interest-bearing accounts. New paragraphs
(e) and (f) are being added to section 560.210 to incorporate two exemptions from the blocking prohibitions that are set forth in
E.O. 13599. These exemptions concern the official business of the Federal Government and the property and interests in
property of the Government of Iran that were blocked pursuant to Executive Order 12170 of November 14, 1979. [10-22-
2012]
242. The ITSR includes revisions to the ITR pertaining to the transfer of funds to or from Iran. Accordingly, how may I
transfer funds to or from Iran that arise from, and are ordinarily incident and necessary to give effect to, an underlying
transaction that is authorized under the ITSR?
The Iranian Transactions and Sanctions Regulations(ITSR) authorize United States depository institutions to process transfers
of funds to or from Iran, or for the direct or indirect benefit of persons in Iran or the Government of Iran , if the transfer arises
from, and is ordinarily incident and necessary to give effect to, an underlying transaction that has been authorized by a specific
or general license issued pursuant to, or set forth in, the ITSR and does not involve debiting or crediting an Iranian account.
See 31 CFR 560.516(a).
In addition, the ITSR authorize United States registered brokers or dealers in securities to process transfers of funds to or from
Iran, or for the direct or indirect benefit of persons in Iran or the Government of Iran, if the transfer arises from, and is ordinarily
incident and necessary to give effect to, an underlying transaction that has been authorized by a specific or general license
issued pursuant to, or set forth in, the ITSR and does not involve debiting or crediting an Iranian account. See 31 CFR
560.516(b).
The authorizations set forth in section 560.516 of the ITSR do not allow a U.S. person who is authorized to engage in the
underlying transaction to deal directly with money service businesses (MSBs) or hawalas, wherever located. However, these
authorizations do not preclude United States depository institutions or United States registered brokers or dealers in securities
from engaging or dealing with third-country MSBs or hawalas in the processing of the authorized transfers pursuant to section
560.516 of the ITSR. [10-22-2012]
243. How can I send personal remittances to or from Iran under the Iranian Transaction and Sanctions Regulations
(ITSR)?
The ITSR authorize the transfer of funds that are noncommercial and personal in nature to or from Iran or for or on behalf of an
individual ordinarily resident in Iran, other than an individual whose property and interests in property are blocked pursuant to §
560.211, subject to certain restrictions and limitations. See 31 CFR 560.550. Such transfers must be processed by a United
States depository institution or a United States registered broker or dealer in securities and not by any other U.S. person. The
personal remittances general license does not permit a U.S. person to deal directly with money service businesses (MSBs) or
hawalas, wherever located. However, this general license does not preclude United States depository institutions or United
States registered brokers or dealers in securities from engaging or dealing with third-country MSBs or hawalas in the
processing of the authorized transfers pursuant to section 560.550 of the ITSR.
The hand-carrying of certain noncommercial, personal remittances is also authorized, provided that the individual who is a U.S.
person is hand-carrying the funds on his or her behalf, but not on behalf of another person. See 31 CFR 560.550. [10-22-2012]
244. What effect will the Iranian Transaction and Sanctions Regulations (ITSR) have on Iranian-Americans and the
people of Iran?
The ITSR include several general licenses that newly authorize, or continue to authorize, activities that are otherwise prohibited
by the regulations. Categories of activities affected by these changes include, among other things, visa-related transactions,
journalistic activities in Iran, the sale of real property in Iran and the transfer of related proceeds to the United States,
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 19/50
educational activities (including certain exchange programs), participation in conferences, and the exportation and
reexportation of medicine and basic medical supplies to Iran. [10-22-2012]
245. What does the Statement of Licensing Procedure on Support of Human Rights-, Humanitarian-, and Democracy-
Related Activities with Respect to Iran do?
The Statement of Licensing Procedure reflects procedures established pursuant to section 413 of the Iran Threat Reduction
and Syria Human Rights Act (the TRA). These procedures stipulate that, as of the effective date of the TRA, license
determinations for complete requests for authorization under this policy shall be made not later than 90 days after receipt by
OFAC, with certain exceptions. The Statement of Licensing Policy applies to applications submitted by the following categories
of U.S. persons seeking to engage in certain human rights-, humanitarian-, and democracy-related activities with respect to
Iran: (1) entities receiving funds from the Department of State to engage in the proposed activity; (2) the Broadcasting Board of
Governors; and (3) other appropriate agencies of the United States Government. The ITSR also include separate statements
of licensing policy related to the sharing of information over the Internet in Iran and the support of democracy and human rights
in Iran and academic and cultural exchange programs. [10-22-2012]
Implementation of Section 504 of the Iran Threat Reduction and Syria Human
Rights Act of 2012 (the TRA)
Print this topic
On August 10, 2012, the President signed into law the Iran Threat Reduction and Syria Human RightsAct of 2012, Public
Law 112-158 (“TRA”). Section 504 of the TRA amends section 1245(d)(4)(D) of the National Defense Authorization Act for
Fiscal Year 2012, Public Law 112-81 (“NDAA”), which the President signed into law on December 31, 2011. The section
504 amendments to the NDAA took effect February 6, 2013. Amendments to the Iranian Financial Sanctions Regulations,
31 C.F.R. part 561 (the “IFSR”) were published on March 15, 2013, to implement sections 503 and 504 of the “TRA” and
certain provisions of Executive Order 13622 of July 30, 2012. Although Executive Order 13716 of January 16, 2016
revoked Executive Order 13622, the relevant provisions of Executive Order 13622 were reimposed by Executive Order 13846
of August 6, 2018.
254. What does section 504 of the TRA do?
Pursuant to the restrictions already in place under the National Defense Authorization Act (NDAA), foreign financial
institutions (“FFIs”) face restrictions on, or loss of, correspondent and payable-through account access in the United States if
they knowingly engage in significant financial transactions with the Central Bank of Iran (“CBI”) or a designated Iranian financial
institution, unless an NDAA exception, such as the significant reduction exception, applies. The NDAA significant reduction
exception applies if the Secretary of State, in consultation with the Secretary of the Treasury and other agencies, has
determined that the country with primary jurisdiction over the FFI has significantly reduced its purchases of Iranian crude oil
during a specified period of time.
Effective February 6, 2013, section 504 amends the NDAA in several ways. Most importantly, it narrows the NDAA’s significant
reduction exception to (a) exempt from sanctions only transactions that conduct or facilitate bilateral trade in goods or services
between the country granted the exception and Iran, and (b) require that funds owed to Iran as a result of the bilateral trade be
credited to an account located in the country granted the exception and not be repatriated to Iran. In addition, it -
(i) eliminates the distinction between state-owned or -controlled FFIs (not including foreign central banks) and private FFIs,
thereby expanding the scope of sanctionable transactions for state-owned or -controlled FFIs with the CBI or designated
Iranian financial institutions; and
(ii) clarifies that countries that have reduced their Iranian crude oil purchases to zero may continue to receive the significant
reduction exception.
The sale of agricultural commodities, food, medicine, or medical devices to Iran (the “Humanitarian Exception”) is not impacted
by section 504 of the TRA.
The purchase or acquisition of petrochemicals from Iran remain sanctionable activities and are not subject to the significant
reduction exception. [2-6-2013]
255. Do the section 504 modifications of the TRA restrict any other dealings with Iran?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 20/50
Yes, the section 504 modifications also narrow the scope of transactions excepted from certain sanctions available under E.O.
13622 . Accordingly, foreign financial institutions (FFIs) in countries that are determined by the Secretary of State to have
significantly reduced their purchases of Iranian crude oil pursuant to the NDAA , that knowingly conduct significant financial
transactions with the National Iranian Oil Company (“NIOC”), the Naftiran Intertrade Company (“NICO”), or otherwise for the
purchase of petroleum or petroleum products from Iran, are only eligible for the significant reduction exception if the FFIs
adhere to the bilateral trade restrictions, credit the funds to an account in the country with primary jurisdiction over the FFI, and
do not repatriate the funds to Iran.
Example 1: A FFI in a country which has received a significant reduction exception and with primary jurisdiction over the FFI
may facilitate a transaction enabling an oil refinery in that country to purchase crude oil from Iran without having exposure to
U.S. correspondent account sanctions, so long as the transaction meets section 504’s bilateral trade requirements, the funds
are credited to an account in the FFI in the country with primary jurisdiction over the FFI, and the funds are not repatriated to
Iran.
Example 2: If, however, a FFI in a country which has received a significant reduction exception facilitates a third country’s
crude oil purchase – even a third country with a significant reduction exception – from Iran, the FFI would have exposure to
sanctions because the transaction was not solely for the FFI host country’s purchase of crude oil from Iran. [2-6-2013]
256. What transactions are impacted by section 504 of the TRA as it amends section 1245 of the National Defense
Authorization Act (NDAA) for Fiscal Year 2012?
Significant financial transactions* knowingly conducted or facilitated by a foreign financial institution (FFI) with the Central Bank
of Iran (CBI) on or after November 5, 2018 or with a designated Iranian financial institution may be subject to sanctions under
the National Defense Authorization Act (NDAA) and section 561.203 of the Iranian Financial Sanctions Regulations (IFSR),
31 C.F.R. Part 561, unless –
(i) the country that has primary jurisdiction over the FFI conducting or facilitating such significant financial transactions has
received a significant reduction exception under section 1245(d)(4)(D) of the NDAA; and
(ii) the significant financial transaction is for bilateral trade only, and any funds owed to Iran as a result of such trade are
credited to an account at the FFI in the country that has primary jurisdiction over the FFI and are not repatriated to Iran.
However, any FFI that knowingly facilitates significant transactions or provides significant financial services for persons
designated in connection with Iran’s support for international terrorism or the proliferation of weapons of mass destruction
pursuant to E.O.s 13224 or 13382 can be sanctioned under section 104(c) of the Comprehensive Iran Sanctions,
Accountability, and Divestment Act of 2010 (“CISADA”) and section 561.201 of the Iranian Financial Sanctions Regulations
(IFSR), even if those transactions are not sanctionable under section 1245(d) of the NDAA, section 561.203 of the IFSR,
sections 1244 and 1247 of the Iran Freedom and Counter-Proliferation Act of 2012, and Executive Order 13846 for countries
that receive an SRE. [11-05-2018]
* These do not include sales relating to the Humanitarian Exception.
257. To which jurisdictions does the significant reduction exception apply (section 504 of the TRA)?
As of February 6, 2013, 20 jurisdictions have been granted a 180-day significant reduction exception.
The following jurisdictions received their 180-day significant reduction exception to the National Defense
Authorization Act (NDAA) sanctions on September 14, 2012: Belgium, the Czech Republic, France, Germany, Greece, Italy,
Japan, the Netherlands, Poland, Spain, and the United Kingdom.
The following jurisdictions received their 180-day significant reduction exception to NDAA sanctions on December 7, 2012:
China, India, Malaysia, Republic of Korea, Singapore, South Africa, Sri Lanka, Taiwan, and Turkey. [2-6-2013]
258. What is meant by the TRA section 504’s requirement that bilateral trade consist of trade in goods and services
between the country with primary jurisdiction over the foreign financial institution (FFI) and Iran?
OFAC interprets bilateral trade between Iran and the country with primary jurisdiction over the FFI to mean trade in only those
goods or services originating in (e.g., produced in or substantially transformed in) –
(i) the country with primary jurisdiction over the FFI conducting or facilitating the transaction, or
(ii) Iran (for purposes of the import of Iranian-origin goods or services by the country with primary jurisdiction over the FFI),
and the trade in services cannot include brokering transactions involving goods or services from or to third countries.
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 21/50
Furthermore, the goods or services must be exported and sold directly to either the country with primary jurisdiction over the
FFI (in the case of Iranian-origin goods or services), or Iran (in the case of goods or services originating in the country with
primary jurisdiction over the FFI).
The Humanitarian Exception is not impacted by section 504’s bilateral trade limitations (see FAQ 265). [2-6-2013]
259. What can a foreign financial institution (FFI) do with the funds resulting from the import of Iranian-origin goods or
services once the funds are credited to an account? Can funds be transferred to other accounts?
Section 504 of the TRA requires that, in order for a sanctionable transaction to fall within the bounds of the significant
reduction exception, any funds owed to Iran as a result of the bilateral trade transaction must be credited to an “account
located in the country with primary jurisdiction over the [FFI].” For purposes of implementing this requirement, OFAC interprets
the “account located in the country with primary jurisdiction over the [FFI]” to be an account in the country with primary
jurisdiction over the FFI, and at the same FFI that facilitated the transaction for the importation of goods or services from Iran.
Once the funds are deposited in the FFI, they can be -
(i) used to pay for a purchase by Iran of goods or services originating in the country with primary jurisdiction over the FFI which
are exported and sold directly to Iran, or for the Humanitarian Exception (see Figure 1); or
(ii) transferred to a SPECIAL PURPOSE ACCOUNT (see FAQ 260) within that same FFI, in the country with primary
jurisdiction over the FFI, where the funds may be later debited to purchase goods or services originating in the country with
primary jurisdiction over the FFI which are exported and sold directly to Iran, or for the Humanitarian Exception (see Figure 2).
The funds may not be repatriated to Iran. [2-6-2013]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 22/50
260. What is a SPECIAL PURPOSE ACCOUNT for purposes of the National Defenese Authorization Act's (NDAA)
significant reduction exception?
A SPECIAL PURPOSE ACCOUNT is an account set up with conditions and safeguards that require the account to be used
only for bilateral trade in goods or services between Iran and the country with primary jurisdiction over the FFI, and for sales
made under the Humanitarian Exception (see FAQ 265). Funds paid as a result of bilateral trade under the NDAA’s significant
reduction exception may be transferred to a SPECIAL PURPOSE ACCOUNT, so long as the account is at the same FFI that
facilitated or conducted the original transaction, in the country with primary jurisdiction over the FFI. [2-6-2013]
261. Are there any circumstances in which funds can be transferred to third-country financial institutions?
Transfers on or after February 6, 2013, of funds deposited in the RECIPIENT ACCOUNT or the SPECIAL PURPOSE
ACCOUNT to third-country financial institutions are not covered by the National Defense Authorization Act's (NDAA )
significant reduction exception, and create exposure to sanctions for FFIs conducting or facilitating such transfers, unless the
transfer is to pay a third-country exporter for sales made pursuant to the Humanitarian Exception (see FAQ 265). [2-6-2013]
262. Can funds be withdrawn from the RECIPIENT ACCOUNT or a SPECIAL PURPOSE ACCOUNT?
In order for the National Defense Authorization Act's (NDAA ) significant reduction exception to apply on or after February 6,
2013, funds withdrawn from the RECIPIENT ACCOUNT or SPECIAL PURPOSE ACCOUNT at the FFI may only be used to
pay for bilateral trade or purchases relating to the Humanitarian Exception. Cash withdrawals from the RECIPIENT ACCOUNT
or SPECIAL PURPOSE ACCOUNT would be deemed to fall outside of the scope of bilateral trade and would expose the FFI to
sanctions. Bank checks written on the account may be used only to pay for bilateral trade or purchases relating to the
Humanitarian Exception, and are subject to further restrictions set out in FAQ 263 below. [2-6-2013]
263. Who can receive payments from funds credited to a RECIPIENT ACCOUNT or SPECIAL PURPOSE ACCOUNT?
In order for the National Defense Authorization Act's (NDAA ) significant reduction exception to apply on or after February 6,
2013, the person receiving payment (e.g., the manufacturer or service provider) for goods or services being exported to Iran
must be –
(i) a citizen, national, or permanent resident of the country with primary jurisdiction over the FFI maintaining the accounts
containing the bilateral trade funds; or
(ii) an entity organized under the laws of the country with primary jurisdiction over the FFI maintaining such accounts.
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 23/50
Furthermore, the person receiving such payment may not be -
(i) the Government of Iran (as defined in 31 CFR Part 561.321) (“GOI”);* or
(ii) a financial institution that appears on the List of Foreign Financial Institutions Subject to Part 561 , which is maintained
on the Office of Foreign Assets Control’s Web site (www.treasury.gov/ofac). [2-6-2013]
*The term “Government of Iran” as defined in 31 CFR Part 561.321 includes: (a) The state and the Government of Iran, as well
as any political subdivision, agency, or instrumentality thereof; (b) Any entity owned or controlled directly or indirectly by the
foregoing; (c) Any person to the extent that such person is, or has been, or to the extent that there is reasonable cause to
believe that such person is, or has been, acting or purporting to act directly or indirectly on behalf of any of the foregoing; and
(d) Any person or entity identified by the Secretary of the Treasury to be the Government of Iran under 31 CFR Part 560.
264. Can funds be remitted to Iran or the Government of Iran (GOI) without exposure to sanctions?
No. If funds from the RECIPIENT ACCOUNT or the SPECIAL PURPOSE ACCOUNT are remitted, directly or indirectly, to Iran,
or paid to any person that is the GOI, the FFI would be exposed to sanctions. [2-6-2013]
265. Can the funds be used for sales made under the Humanitarian Exception?
The National Defense Authorization Act of Fiscal Year 2012 (NDAA) generally exempts from sanctions sales made under
the Humanitarian Exception (i.e., the sale of agricultural commodities, food, medicine, or medical devices from third countries
to Iran). Funds deposited in the RECIPIENT ACCOUNT or the SPECIAL PURPOSE ACCOUNT can be used to pay for sales
made pursuant to the Humanitarian Exception. [2-6-2013]
314. Can an exporter of agricultural commodities, food, medicine, or medical devices get paid out of a Central Bank of
Iran (CBI) account at a foreign financial institution (FFI) in a country with a significant reduction exception, even
though the exporter is located in a third-country? Can the third-country exporter’s bank handle this transaction?
Yes. So long as the transaction does not involve a designated individual or entity, banks on the Part 561 List located on OFAC’s
website (http://www.treasury.gov/ofac/downloads/561list.pdf ), or otherwise proscribed conduct, such transactions are not
sanctionable under U.S. law. Furthermore, there is no requirement under U.S. law that agricultural commodities, food,
medicine, or medical devices be routed through the country with the significant reduction exception.
Such a payment mechanism is not the exclusive mechanism for the purchase of agricultural commodities, food, medicine, or
medical devices under U.S. law. Other options include receiving payment from a third-country account of the CBI or a nondesignated
Iranian financial institution.
The Department of the Treasury Office of Foreign Assets Control regulations describe the exception for transactions relating to
agricultural commodities, food, medicine, or medical devices in 31 CFR § 561.203(g) and Note 2 to 51 CFR § 561.203.
Additional information and clarifying guidance about humanitarian assistance and related exports to the Iranian people can be
found at http://www.treasury.gov/resource-center/sanctions/Programs/Documents/hu… . [6-2013]
266. Does the November 8, 2012 designation of National Iranian Oil Company (NIOC) under E.O. 13382 impact the
scope of permissible transactions by foreign financial institutions (FFIs) in significantly reducing countries?
Yes. On September 24, 2012, NIOC was identified as an agent or affiliate of Iran’s Islamic Revolutionary Guard Corps (“IRGC”)
under section 312 of the TRA , and designated on November 8, 2012, under E.O. 13382 for providing services and support
to the IRGC. Accordingly, the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) applies to
transactions with NIOC. As a result of these additional sanctions against NIOC, only transactions solely for the purchase of
petroleum or petroleum products from NIOC will fall within the scope of the significant reduction exception. A FFI in a
significantly reducing country that is found to knowingly conduct or facilitate other types of significant transactions with NIOC
(i.e., transactions unrelated to the purchase of petroleum or petroleum products from Iran) would face exposure to CISADA
sanctions.
Example 3: If a FFI in a country with a significant reduction exception facilitates a transaction enabling a company in that
country to purchase drilling equipment from NIOC, the FFI risks restrictions on, or loss of, correspondent and payable-through
account access in the United States, because the transaction was not solely for the purchase of petroleum or petroleum
products from Iran. [2-6-2013]
267. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “food,
medicine, and medical devices,” “foreign financial institution,” and “country with primary jurisdiction over the FFI,”?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 24/50
These definitions are set out in 31 CFR Part 561. [2-6-2013]
Iran Freedom and Counter-Proliferation Act of 2012 (IFCA)
Print this topic
Certain statutory provisions of the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) were previously implemented
through E.O. 13645 of June 3, 2013, which was revoked by E.O. 13716 of January 16, 2016. E.O. 13716, which also
carried forward certain IFCA implementation authorities, was revoked by E.O. 13846 of August 6, 2018, “Reimposing
Certain Sanctions With Respect to Iran”. Please be advised that certain provisions of E.O. 13645, including IFCA
implementation authorities, have been incorporated into the New E.O. FAQs relating to E.O. 13846 can be found here. FAQs
relating to E.O. 13645 have been archived and can be found here.[08-06-18]
General Questions (Print)
313. What is the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA)?
IFCA was signed into law on January 2, 2013, as a part of the National Defense Authorization Act for Fiscal Year 2013, and
provides for several new sanctions related to Iran. IFCA authorizes broad sanctions on: certain activities related to Iran’s
energy, shipping, and shipbuilding sectors; the sale, supply, or transfer to or from Iran of precious and certain other metals,
graphite, coal, and industrial software; the provision of underwriting services, insurance, or reinsurance to activities and
persons targeted by U.S. sanctions against Iran; financial transactions involving sanctioned Iranian individuals and entities; and
persons involved in the diversion of goods intended for the Iranian people. Most of the IFCA provisions target conduct
occurring on or after July 1, 2013.
The U.S. Department of the Treasury will be issuing regulations to implement certain provisions in IFCA. In addition, the U.S.
Department of State expects to adopt an interpretation of IFCA similar to that set forth below. [06-03-13]
289. How will the following Iran Freedom and Counter-Proliferation Act (IFCA) terms be interpreted: “Iran,”
“knowingly,” “significant,” and “transfer”?
As a general matter, we intend to rely, where applicable, on definitions of terms previously included in Treasury regulations.
“Iran”
The Iranian Financial Sanctions Regulations (31 CFR part 561) (IFSR) define “Iran” as the Government of Iran and the territory
of Iran and any other territory or marine area, including the exclusive economic zone and continental shelf, over which the
Government of Iran claims sovereignty, sovereign rights, or jurisdiction, provided that the Government of Iran exercises partial
or total de facto control over the area or derives a benefit from economic activity in the area pursuant to international
arrangements. (31 CFR § 561.329)
“knowingly”
The IFSR define “knowingly” with respect to conduct, a circumstance, or a result, to mean that a person has actual knowledge,
or should have known, of the conduct, the circumstance, or the result. (31 CFR § 561.314)
“significant”
As a general matter, in determining for purposes of IFCA and relevant Executive orders whether transactions, financial
transactions, or financial services are significant, the Department of the Treasury will rely on the interpretation set out in
§561.404 of the IFSR. The IFSR provide that the Department of the Treasury may consider the totality of the facts and
circumstances set forth a list of broad factors that can play a role in the determination whether transactions, financial services,
and financial transactions are significant, including: (a) the size, number, and frequency of the transactions, financial services,
or financial transactions; (b) the natureof the transactions, financial services, or financial transactions, including their type,
complexity, and commercial purpose; (c) the level of awareness of management and whether the transactions are part of a
pattern of conduct; (d) the nexus of the transactions, financial services, and financial transactions and blocked persons; (e) the
impact of the transactions, financial services, and financial transactions on statutory objectives; (f) whether the transactions,
financial services, and financial transactions involve deceptive practices; (g) whether the transactions solely involve the passive
holdings of Central Bank of Iran (CBI) reserves or repayment by the CBI of official development assistance or the transfer of
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 25/50
funds required as a condition of Iran’s membership in an international financial institution; and (h) other relevant factors that the
Secretary of the Treasury deems relevant. We anticipate adopting a similar approach to interpreting the term “significant” as it
applies to goods or services. (31 C.F.R. §561.404)
“transfer”
We anticipate that regulations to be promulgated will define “transfer” to include import, transshipment, export, or reexport,
whether direct or indirect. [08-06-18]
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?
There is no general exception for payments, sales, deliveries, or transfers arising out of contracts entered into prior to July 1,
2013, on or after which date certain activities become sanctionable under IFCA . The assessment of whether such
payments are “significant” or result in the transfer of “significant goods or services” or “significant financial support” will be done
on a case-by-case basis in line with the criteria discussed above. [06-03-13]
292. What are the implications of IFCA on the provision of humanitarian goods to the people of Iran?
IFCA generally excepts from sanctions transactions for the sale of agricultural commodities, food, medicine, or medical
devices to Iran, as set out in more detail in Q&As 297 and 304.[08-06-18]
Sanctions Relating to Iran’s Energy, Shipping, and Shipbuilding Sectors (Print)
293. What will the “energy, shipping, and shipbuilding sectors of Iran” mean for the purposes of IFCA?
We anticipate that regulations to be promulgated will define “energy sector of Iran” to include activities involving the exploration,
extraction, production, refinement, or liquefaction of petroleum, natural gas, or petroleum products in Iran. (See also discussion
of activities involving natural gas in Q&A 297.)
We anticipate that regulations to be promulgated will define “shipping sector of Iran” to include activities involving the
transportation of goods by seagoing vessels, including oil tankers and cargo vessels, flying the flag of the Islamic Republic of
Iran, or owned, controlled, chartered, or operated directly or indirectly by the Government of Iran.
We anticipate that regulations to be promulgated will define “shipbuilding sector of Iran” to include activities involving the
construction of seagoing vessels, including oil tankers and cargo vessels, in Iran. [08-06-18]
294. How will I know if someone is part of Iran’s energy, shipping, or shipbuilding sectors or is a port operator in Iran?
Persons determined to be part of Iran’s energy, shipping, or shipbuilding sectors, or a port operator in Iran for purposes
of IFCA section 1244(c) will be identified as such on the SDN List. Knowingly providing certain significant support to
persons determined to be part of Iran’s energy, shipping, or shipbuilding sectors, or a port operator in Iran will have exposure to
sanctions, unless the transaction is excepted (see also Q&A 297). [06-03-13]
295. What are goods or services used in connection with Iran’s energy, shipping, or shipbuilding sectors for purposes
of IFCA section 1244(d)(3)?
We anticipate that regulations to be promulgated will define goods and services used in connection with Iran’s energy, shipping
and shipbuilding sectors to include:
a. Energy Sector: In the case of Iran’s energy sector, goods or services that contribute to,
Iran’s ability to develop its domestic petroleum resources;
The maintenance or expansion of Iran’s domestic production of petroleum products; and
Iran’s ability to import or export petroleum or petroleum products.
b. Shipping Sector: In the case of Iran’s shipping sector,
The provision of crude and product tankers to Iran;
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 26/50
The provision of registry, flagging, or classification services of any kind;
The supervision of and participation in the repair of ships and their parts;
The inspection, testing, and certification of marine equipment materials and components;
The carrying out of surveys, inspections, audits and visits, and the issuance, renewal or endorsement of the relevant
certificates and documents of compliance, as they relate to ships and shipping; and
Any other goods or services relating to the maintenance, supply, bunkering, and docking of vessels flying the flag of the
Islamic Republic of Iran, or owned, controlled, chartered, or operated directly or indirectly by, or for or on behalf of the
Government of Iran (GOI) or an Iranian person.
c. Shipbuilding Sector: In the case of Iran’s shipbuilding sector,
The building and refit of vessels;
The provision or refit of items such as (i) steam turbines and their parts for marine propulsions, (ii) marine propulsion
engines and parts used solely or principally with them, (iii) other gas turbines for marine propulsion, (iv) ship or boat
propellers and blades, and (v) direction finding compasses and other navigational instruments and appliances solely for
the maritime industry;
Other goods used in connection with building and propulsion of vessels; and
Technical assistance and training relating to, and financing of, the building, maintenance or re-fitting of vessels.
Sections 1244(d)(1) and (2) of IFCA make sanctionable certain transactions for the sale, supply, or transfer to or from Iran
of such goods and services if they are significant goods or services used in connection with Iran’s energy, shipping, or
shipbuilding sectors. (See Q&A 289 above for an interpretation of “significant.”) The provision of goods or services identified
above could be sanctionable regardless of whether any person involved in the transaction has been determined to be part of
Iran’s energy, shipping, or shipbuilding sectors. [06-03-13]
296. Will payment for bunkering of third-country ships carrying non-sanctionable goods to or from Iran be subject to
sanctions?
If a non-Iranian vessel is transporting non-sanctionable goods to or from Iran, bunkering in a third country will not be subject to
sanctions provided that no other sanctionable activity is involved. [06-03-13]
297. Are there any exceptions to the sanctions provisions of section 1244 of IFCA?
The following transactions are excepted from the provisions of section 1244 of IFCA .
a. Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran or for the provision of
humanitarian assistance to the people of Iran.
b. The export of petroleum or petroleum products from Iran to a country with a significant reduction exception under section
1245(d)(4)(D)(i) of the National Defense Authorization Act for Fiscal Year 2012 (NDAA 2012).
c. A significant financial transaction conducted or facilitated by a foreign financial institution (FFI), provided that a significant
reduction exception under 1245(d)(4)(D)(i) of NDAA 2012 applies to the country with primary jurisdiction over the FFI and the
financial transaction is for trade in goods or services (i) between Iran and the country with primary jurisdiction over the FFI and
(ii) not otherwise subject to sanctions under the law of the United States, and any funds owed to Iran as a result of the trade
are credited to an account located in the country with primary jurisdiction over the FFI. We anticipate the implementation of
these trade requirements to be similar to the trade requirements set forth in the Iranian Financial Sanctions Regulations (IFSR),
in particular 31 CFR §561.203(j) and 31 CFR §561.203(k).
d. The sale, supply, or transfer of natural gas to or from Iran. IFCA section 1244, however, does set out sanctions that may
apply to FFIs that conduct or facilitate a transaction for the sale, supply, or transfer of natural gas to or from Iran unless the
financial transaction is for trade in goods or services (i) between Iran and the country with primary jurisdiction over the FFI and
(ii) not otherwise subject to sanctions under the law of the United States, and any funds owed to Iran as a result of the trade
are credited to an account located in the country with primary jurisdiction over the FFI. We anticipate the implementation of
these trade requirements to be similar to the trade requirements set forth in the IFSR, in particular 31 CFR §561.203(j) and 31
CFR §561.203(k).
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 27/50
e. Certain activities relating to the pipeline project to supply natural gas from the Shah Deniz gas field in Azerbaijan to Europe
and Turkey. [08-06-18]
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?
Any company involved in loading or unloading cargo in Iran should exercise great caution to avoid engaging in transactions
with entities designated by the United States, including the Tidewater Middle East Co. which was designated for its involvement
in Iran’s proliferation of weapons of mass destruction. However, to the extent that a shipping company transacts with port
operators in Iran that have been identified as such under IFCA but not otherwise designated, and as long as such
payments are limited strictly to routine fees including port dues, docking fees, or cargo handling fees, paid for the loading and
unloading of non-sanctioned goods at Iranian ports, we anticipate that such transactions would not be considered significant
transactions for the purposes of IFCA. Non-routine and/or large payments or fees that materially exceed standard industry
rates could expose a person to sanctions. Furthermore, providing any port operator in Iran with any significant financial,
material, technological, or other support could expose a person to sanctions. [08-06-18]
Sanctions Relating to the Sale, Supply, or Transfer of Certain Materials to or from Iran (relating to IFCA) (Print)
IFCA provides for sanctions involving the sale, supply, or transfer of certain materials to or from Iran.
298. For purposes of IFCA, what materials are considered graphite, raw or semi-finished metals?
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 single or complex borides
of titanium; beryllium metal and its alloys; boron metal and its alloys; cobalt metal and its alloys; copper infiltrated tungsten
metal; copper-beryllium metal; germanium metal and its alloys; graphites; hastelloy; inconel; magnesium metal and its alloys;
molybdenum metal and its alloys; neptunium-237 metal and its alloys; nickel metal and its alloys; nickel aluminide metals;
niobium metal and its alloys; niobium-titanium filaments; plutonium metal and its alloys; porous nickel metal; silver infiltrated
tungsten metal; tantalum metal and its alloys; tellurium metal and its alloys; titanium aluminide metals; titanium metal and its
alloys; tungsten metal, tungsten carbide metal, and their alloys; uranium titanium alloy metals; and zirconium metal and its
alloys and compounds. [06-03-13]
299. For purposes of IFCA, what are considered precious metals?
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 plated with platinum, unwrought or in semi-manufactured forms, or in powder form); base metals or silver, clad
with gold, not further worked than semi-manufactured; platinum, unwrought or in semi-manufactured forms, or in powder form;
iridium; osmium; palladium; rhodium; ruthenium; base metals, silver or gold, clad with platinum, not further worked than semimanufactured;
waste and scrap of precious metal or of metal clad with precious metals, other waste and scrap containing
precious metal or precious-metal compounds, of a kind used principally for the recovery of precious metal. [06-03-13]
300. For purposes of sanctions under section 1245, how will I know which sectors are controlled by Iran’s Islamic
Revolutionary Guard Corps?
Pursuant to delegated authority, the Secretary of State issues periodic reports pursuant to section 1245(e) of IFCA with respect
to which sectors of the Iranian economy are controlled directly or indirectly by Iran’s Islamic Revolutionary Guard Corps
(IRGC). Given the opaque business environment in Iran and the significant role that the IRGC plays in the Iranian economy,
OFAC recommends that a person considering business in Iran or with Iranian persons conduct due diligence sufficient to
ensure that it is not knowingly engaging in transactions with the IRGC, or its officials, agents, or affiliates. [08-06-18]
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?
A FFI, prior to conducting or facilitating a significant financial transaction for the sale, supply, or transfer to or from Iran of the
materials listed in 1245(d) – as described in part in Q&A 298– will need to undertake due diligence to ensure that the
transaction does not involve the materials being sold, supplied, or transferred, directly or indirectly, to or from Iran for
sanctionable uses under section 1245. Pursuant to delegated authority, the Secretary of State issues periodic reports pursuant
to section 1245(e) of IFCA, which contains determinations on which materials identified in section 1245(d) are used by Iran as
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 28/50
a medium for swap or barter, are listed as assets on the national balance sheet of Iran, or are used in connection with the
nuclear, military, or ballistic missile programs of Iran. [08-06-18]
302. Are there any exceptions to section 1245 of IFCA?
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 established and enforced official policies, procedures,
and controls to ensure that the person does not sell, supply, or transfer to or from Iran, or facilitate or conduct a significant
financial transaction to sell supply, or transfer to or from Iran, materials listed in section 1245 as sanctioned under section 1245.
The Department of the Treasury or the Department of State, as appropriate, will make this determination on a case by case
basis as part of an investigation or enforcement action by the relevant Department. [06-03-13]
Sanctions Relating to Insurance, Reinsurance, or Underwriting (relating to IFCA) (Print)
303. Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA's section
1246(a)(1)?
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 Iran. [06-03-13]
304. Are there exceptions to insuring, reinsuring, or underwriting sanctioned activities?
Yes. IFCA includes the following exceptions to insuring, reinsuring, or underwriting sanctioned activities.
a. Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran or for the provision of
humanitarian assistance to the people of Iran can be insured, reinsured, or underwritten.
b. A person that provides insurance, reinsurance, or underwriting services to sanctioned activity, if a determination is made by
the Department of the Treasury or the Department of State, as appropriate, that the person has established and enforced
official policies, procedures, and controls to ensure that the person does not underwrite or enter into a contract to provide
insurance or reinsurance for activities targeted under section 1246 of IFCA. The Department of the Treasury or the Department
of State, as appropriate, will make this determination on a case by case basis as part of an investigation or enforcement action
by the relevant Department. [06-03-13]
Executive Order 13645 of June 3, 2013, "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. 13645 was revoked by E.O. 13716 of January 16, 2016. Please be advised that certain provisions of E.O. 13645 have
been incorporated into E.O. 13846 of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran”. FAQs relating
to E.O. 13846 can be found here. FAQs relating to E.O. 13645 have been archived and can be found here.
General Licenses (GL) for Agricultural Commodities, Medicine, and Medical
Devices in the Iranian Transactions and Sanctions Regulations
Print this topic
318. Does the GL for medical devices authorize the exportation or reexportation of all medical devices?
No. The GL for medical devices appearing at section 560.530(a)(3)(i) of the Iranian Transactions and Sanctions Regulations
(ITSR) authorizes covered persons, as defined in section 560.530(e)(4), to export or reexport to Iran medical devices as
defined in section 560.530(e)(3) of the ITSR, except for items on the List of Medical Devices Requiring Specific
Authorization , which is maintained on OFAC’s website. This list will be published in the Federal Register, as will any
changes to the list. [12-22-16]
319. Does the GL for medical devices authorize the exportation or reexportation of these items to all entities in Iran?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 29/50
No. While the GL under section 560.530(a)(3)(i) of the Iranian Transactions and Sanctions Regulations (ITSR) authorizes
exports or reexports of certain medical devices to most entities in Iran, it does not authorize exports or reexports to military,
intelligence, or law enforcement purchasers or importers, nor does it authorize exports or reexports to persons whose property
and interests in property are blocked under any of the programs administered by OFAC, except for persons whose property
and interests in property are blocked solely pursuant to Executive Order 13599 and the ITSR. When engaging in activities
pursuant to this GL, exporters and reexporters are expected to undertake due diligence regarding all parties to the
transactions, just as they would when acting pursuant to a specific license issued by OFAC. [12-22-16]
361. What items and persons are excluded from the agricultural commodities general license in the Iranian
Transactions and Sanctions Regulations (ITSR)?
The specified items excluded from the scope of the agricultural commodities general license are: castor beans, castor bean
seeds, certified pathogen-free eggs (unfertilized or fertilized), dried egg albumin, live animals (excluding live cattle, shrimp, and
shrimp eggs), embryos (excluding cattle embryos), Rosary/Jequirity peas, non-food-grade gelatin powder, peptones and their
derivatives, super absorbent polymers, western red cedar, and all fertilizers.
The persons excluded from the scope of the agricultural commodities general license are Iranian military, intelligence, or law
enforcement purchasers or importers. In addition, the agricultural commodities general license does not authorize exports or
reexports to persons whose property and interests in property are blocked under any of the programs administered by OFAC,
except for persons whose property and interests in property are blocked solely pursuant to Executive Order 13599 and the
ITSR.
Exports or reexports involving the excluded items or excluded persons discussed above continue to require the level of review
afforded by specific licensing and therefore are not authorized by the agricultural commodities general license. [12-22-16]
362. Is the exportation or reexportation of non-U.S.-origin agricultural commodities, medicine, or medical devices by a
U.S. person to Iran authorized?
Yes. The definitions of the terms “agricultural commodities,” “medicine,” and “medical device” used in the relevant general
licenses in the ITSR include, in the case of items subject to Commerce's Export Administration Regulations(EAR), items that
are designated as EAR99 and, in the case of items not subject to the EAR, items that would be designated as EAR99 if they
were located in the United States. For example, under the agricultural commodities general license, a company located in the
United States would be authorized to arrange for the exportation from a third country to Iran of agricultural commodities
produced in the third country if those commodities would be designated as EAR99 if they were located in the United States,
provided that all conditions of the general license are otherwise satisfied. [12-22-16]
363. Is the exportation or reexportation by non-U.S. persons of agricultural commodities, medicine, or medical
devices that are subject to the Export Administration Regulations (EAR) to Iran authorized?
Yes. A non-U.S. person may export or reexport agricultural commodities, medicine, or medical devices to Iran under the
relevant general licenses in the ITSR, provided that the items are subject to Commerce's Export Administration
Regulations(EAR) and all conditions of the relevant general license are otherwise satisfied. For example, a non-U.S. person
would be authorized under the medicine and medical devices general license to arrange for the exportation or reexportation to
Iran of EAR99 medicines located in the United States or a third country.
In addition, an entity owned or controlled by a U.S. person and established or maintained outside the United States (a “U.S.-
owned or -controlled foreign entity”) may export or reexport agricultural commodities, medicine, and medical devices to Iran
under the relevant general licenses in the ITSR (including both items subject to the EAR and items not subject to the EAR),
provided that all conditions of the relevant general license are otherwise satisfied. For example, a U.S.-owned or -controlled
foreign entity would be authorized under the medicine and medical devices general license to arrange for the reexport to Iran of
EAR99 medicines, as well as the export to Iran of medicines not subject to the EAR (e.g., medicines produced outside the U.S.
by a non-U.S. person with no controlled U.S. content) that would be designated as EAR99 if they were located in the United
States. [12-22-16]
364. Who can apply for a specific license if an export or reexport to Iran is not authorized by general license?
If an export or reexport is not authorized by general license, any U.S. person, or non-U.S. person exporting items subject
to Commerce's Export Administration Regulations EAR and designated as EAR99, wherever located, or U.S.-owned or -
controlled foreign entity may apply for a specific license. For example, a U.S.-owned or -controlled foreign entity may apply for
a specific license for the export or reexport to Iran of agricultural commodities excluded from the scope of the agricultural
commodities general license, such as live animals. [12-22-16]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 30/50
365. What is authorized with respect to brokerage services related to exports or reexports of agricultural
commodities, medicine, or medical devices to Iran?
U.S. persons continue to be authorized to provide brokerage services on behalf of U.S. persons for the sale and exportation or
reexportation by U.S. persons of agricultural commodities, medicine, and medical devices to Iran, provided that the sale and
exportation or reexportation itself is authorized by either general or specific license. [4-7-2014]
366. Do I still need to come in to OFAC for a specific license to export certain types of agricultural commodities to
Iran?
OFAC will no longer issue specific licenses for exports or reexports that are covered by the agricultural commodities general
license in the ITSR.
However, a small number of specified agricultural commodities and certain persons are excluded from the agricultural
commodities general license and continue to require the level of review afforded by specific licensing. As a result, persons
seeking authorization for the exportation or reexportation to Iran of castor beans, castor bean seeds, certified pathogen-free
eggs (unfertilized or fertilized), dried egg albumin, live animals (excluding live cattle, shrimp, and shrimp eggs), embryos
(excluding cattle embryos), Rosary/Jequirity peas, non-food-grade gelatin powder, peptones and their derivatives, super
absorbent polymers, western red cedar, or all fertilizers, or for the exportation or reexportation of any agricultural commodities
to Iranian military, intelligence, or law enforcement purchasers or importers, must still apply for a specific license from OFAC.
The agricultural commodities general license in the ITSR also does not authorize exports or reexports to persons whose
property and interests in property are blocked under any of the programs administered by OFAC, except for persons whose
property and interests in property are blocked solely pursuant to Executive Order 13599 and the ITSR. [12-22-16]
367. What is the definition of a “bioactive peptide”?
For purposes of the relevant exclusion from the agricultural commodities general license in the Iranian Transactions and
Sanctions Regulations(ITSR), the term “bioactive peptide” means an item that must be less than 50 amino acids in length and
bioactive (antioxidant, antiallergic, antimicrobial, antithrombotic, antiatherogenic, hypoglycaemic, anti-inflammatory, antitumor,
cytostatic, immunosuppressive properties, or hepatoprotective properties.) [4-7-2014]
Amendments to the General Licenses for the Exportation or Reexportation of
Agricultural Commodities, Medicine, and Medical Devices to Iran
Print this topic
482. What key changes did the December 23, 2016 regulatory amendment to the Iranian Transactions and Sanctions
Regulations (ITSR) make relating to the exportation and reexportation of agricultural commodities, medicine, and
medical devices to Iran?
The amendment primarily expands the scope of medical devices that can be exported or reexported to Iran without specific
authorization. It authorizes the exportation or reexportation to Iran of all items meeting the definition of the term “medical
device” as defined in section 560.530(e)(3) of the ITSR, except for certain excluded persons as well as certain medical devices
that are excluded from the authorization and published on the List of Medical Devices Requiring Specific Authorization. The
exportation and reexportation of items on the List of Medical Devices Requiring Specific Authorization or to excluded persons
requires a specific license from OFAC. The amendment also adds shrimp and shrimp eggs to the list of agricultural
commodities that may be exported to Iran without specific authorization, other than to certain excluded persons.
In addition, the amendment authorizes covered persons to provide training, other than to certain excluded persons, necessary
and ordinarily incident to the safe and effective use of agricultural commodities, medicine, and medical devices exported or
reexported pursuant to section 560.530 of the ITSR. It also authorizes the importation into the United States of certain U.S.-
origin agricultural commodities, medicine, and medical devices that were previously exported or reexported to Iran pursuant to
the authorizations in section 560.530 of the ITSR and that are broken, defective, or non-operational, or are connected to
product recalls, adverse events, or other safety concerns. Additionally, the amendment authorizes the exportation or
reexportation to Iran, and storage within Iran for future use, of a limited number of replacement parts for certain medical
devices previously exported or reexported to Iran pursuant to an OFAC license to replace broken or non-operational
components or where it is ordinarily incident and necessary to proper preventative maintenance of the medical device, and the
exportation or reexportation of software and services related to the operation, maintenance, and repair of medical devices. [12-
22-16]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 31/50
483. How does an exporter determine which medical devices need to be specifically licensed by OFAC for exportation
or reexportation to Iran?
An exporter should refer to the List of Medical Devices Requiring Specific Authorization , which is maintained on OFAC’s
website, www.treasury.gov/ofac, on the Iran Sanctions page. An exporter must obtain a specific license from OFAC to export or
reexport any medical device on that list to Iran. An exporter must also obtain a specific license for exports to excluded persons
as defined in section 560.530(a)(3)(iv) of the ITSR. [12-22-16]
484. What types of training activities are considered to be necessary and ordinarily incident to the safe and effective
use of medicine and medical devices?
OFAC considers training activities including the dissemination of product information on the intended use of the device;
comparisons of other devices and options; and the manufacturer’s instructions for use, labeling, warning, contraindications,
storage, and maintenance of the medicine or device to be necessary and ordinarily incident to the safe and effective use of
medicines and medical devices. Other examples include training health care professionals to use medical devices safely in
order to achieve the desired patient outcome, training on procedures for cleaning and inspecting devices regularly to ensure
they are functioning correctly, ongoing training and periodic testing to ensure users stay competent, and training on procedures
for adverse events or device failure. [12-22-16]
Licenses Authorizing Exports of Agricultural Commodities, Medicine, and Medical Devices
For information regarding licenses authorizing exports of agricultural commodities, medicine, and medical devices to Iran and
Sudan pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), please see the following topic.
Amendment to the Definition of “Iranian-origin goods” or “goods of Iranian origin” in the Iranian Transactions and
Sanctions Regulations (ITSR)
Print this topic
485. What key changes did the December 23, 2016 regulatory amendment to the Iranian Trade and Sanctions
Regulations (ITSR) make to the definition of “Iranian-origin goods” or “goods of Iranian origin”?
OFAC amended section 560.306 of the ITSR to clarify that the terms “goods of Iranian origin” and “Iranian-origin goods” do not
include the following categories of goods, provided that such goods were not grown, produced, manufactured, extracted, or
processed in Iran: (i) goods exported or reexported to Iran under an authorization issued pursuant to the ITSR (e.g., a medical
device or a personal communications device exported or reexported to Iran pursuant to a general or specific license issued
pursuant to the ITSR) and that subsequently have been reexported from and are located outside of Iran, or (ii) goods
transported on a vessel or aircraft that passed though Iranian territorial waters or stopped at a port or place in Iran en route to a
destination outside of Iran and that have not otherwise come into contact with Iran. [12-22-16]
486. What is an example of goods otherwise coming into contact with Iran?
Goods have come into contact with Iran, if, for example, they are removed from a port or airport in Iran or are processed
through Iranian customs, or if they transit Iran by truck or train en route to a destination outside of Iran. [12-22-16]
487. Are goods that are unloaded from a ship in an Iranian port, put on a truck, and driven out of the boundaries of the
port or place of unloading considered to be Iranian-origin goods?
Yes. These goods have otherwise come in contact with Iran and thus do not fall within the carve-out to the definition of Iranianorigin
goods or goods of Iranian-origin at section 560.306 (b)(2) of the ITSR . However, if these goods are being exported or
reexported to Iran under an authorization issued pursuant to the ITSR and they subsequently are reexported from and are
located outside of Iran, they would fall within the carve-out to the definition of Iranian-origin goods or goods of Iranian-origin at
section 560.306(b)(1) of the ITSR. [12-22-16]
488. Are goods that are unloaded from a ship in an Iranian port, moved within the boundaries of the port, and loaded
onto a second ship en route to a destination outside of Iran, without ever leaving the port considered to be Iranianorigin
goods?
No, provided that they have not otherwise come in contact with Iran. [12-22-16]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 32/50
Iranian General License D-1
Print this topic
On May 30, 2013, the Department of the Treasury, in consultation with the Departments of State and Commerce, issued
General License D (“GL D”) authorizing the export and reexport to Iran of certain hardware, software, and services incident to
personal communications. On February 7, 2014, the Department of the Treasury, in consultation with the Departments of State
and Commerce, issued amended Iranian General License D-1 (“GL D-1”) , which clarifies certain aspects of GL D and adds
certain new authorizations. Effective February 7, 2014, GL D-1 replaces and supersedes in its entirety GL D.
General Questions (Print)
337. What are key changes made by amended General License D-1?
First, GL D-1 expands the authorization in GL D to permit the exportation, reexportation, or provision, directly or indirectly,
to Iran of certain personal communications software, hardware, and related services subject to Commerce's Export
Administration Regulations, 15 C.F.R. parts 730 through 774 (“EAR”) (rather than just the exportation or reexportation from the
United States or by a U.S. person of such software, hardware, and services). See GL D-1, paragraphs (a)(2)(i) & (a)(3). For
purposes of GL D-1, the term “provision” could include, for example, an in-country transfer of covered software or hardware.
The general license now authorizes, for example, a non-U.S. person located outside the United States to export certain
hardware and software subject to the EAR to Iran. See FAQ #341.
Second, GL D-1 adds new authorizations for the exportation, reexportation, or provision, directly or indirectly, by a U.S. person
located outside the United States to Iran of certain software and hardware not subject to the EAR. See GL D-1 , paragraphs
(a)(2)(ii) & (a)(3). The general license now authorizes, for example, a U.S. company to export to Iran, from a location outside
the United States, certain hardware or software that is not subject to the EAR (including foreign-origin hardware or software
containing less than a de minimis amount of U.S. controlled content). See FAQ #342.
Third, a new Note has been added to paragraphs (a)(2) and (a)(3) clarifying that the authorization in those paragraphs includes
the exportation, reexportation, or provision, directly or indirectly, of the authorized items by an individual leaving the United
States for Iran. GL D-1 also adds a new authorization for the importation by an individual into the United States of certain
hardware and software previously exported by the individual to Iran pursuant to other provisions of GL D-1 or 31 C.F.R. §
560.540. See GL D-1 , paragraph (a)(5). The general license now authorizes, for example, an individual to carry a
smartphone that falls within the scope of the GL D-1 authorization while traveling to and from Iran. See FAQ #343.
Finally, to further ensure that the sanctions on Iran do not have an unintended chilling effect on the willingness of companies to
make available certain publicly available, no cost personal communications tools to persons in that country, GL D-1 adds a new
authorization related to the potential recipients of certain publicly available, no cost services and software. See GL D-1 ,
paragraph (a)(6).
Notwithstanding these changes, nothing in this general license relieves an exporter from compliance with the export license
requirements of another Federal agency. [02-07-2014]
338. With respect to GL D-1 authorizations in paragraphs (a)(1) and (a)(2), what services and software are covered?
Qualifying services or software must be “incident to the exchange of personal communications over the Internet.” In addition,
qualifying software under paragraph (a)(2) must meet the stated export control-related criteria. Both paragraphs provide an
illustrative but not exhaustive list of the types of services that are authorized: “instant messaging, chat and email, social
networking, sharing of photos and movies, web browsing, and blogging.” See FAQ #344 and OFAC’s Interpretive Guidance
and Statement of Licensing Policy on Internet Freedom in Iran (March 20, 2012), available at http://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/internet_freedom.pdf.
Qualifying services or software need not be specifically listed in the Annex in order to be authorized by paragraphs (a)(1) or (a)
(2), provided that they otherwise meet the requirements of paragraphs (a)(1) or (a)(2). [02-07-2014]
339. With respect to GL D-1 authorization in paragraph (a)(3), do exporters need to make a determination as to
whether an export of an item or service listed in the Annex to GL D-1 is “incident to personal communications”?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 33/50
No. The Annex lists software, hardware, and related services determined to be “incident to personal communications” for
purposes of the authorization in paragraph (a)(3) of GL D-1 . [02-07-2014]
340. What should I do if I am unsure whether an item or service is covered by GL D-1?
If you require assistance interpreting the authorizations contained in GL D-1 and how they apply to your situation, please
contact OFAC’s Licensing Division online at http://www.treasury.gov/resource-center/sanctions/Pages/licensing.aspx, by phone
at 202-622-2480, or by email at [email protected]. [02-07-2014]
341. May a non-U.S. person export, reexport, or provide to Iran hardware and software that is subject to Commerce's
Export Administration Regulations (EAR) pursuant to GL D-1?
Yes, for purposes of the authorities administered by OFAC, amendments made by GL D-1 authorize the exportation,
reexportation, or provision of certain hardware and software subject to the EAR by non-U.S. persons outside the United States.
See GL D-1 , paragraphs (a)(2)(i) & (a)(3). For example, a non-U.S. person manufacturer of smartphones that are (a)
subject to the EAR because they contain more than a de minimis amount of U.S. controlled content and (b) within the scope of
the GL D-1 authorization may export the smartphones from its third-country manufacturing facility directly or indirectly to Iran.
See FAQ #337. [02-07-2014]
342. Does GL D-1 authorize U.S. persons located outside the United States to export or reexport to Iran certain
specified hardware or software that is not subject to Commerce's Export Administration Regulations (EAR)?
Yes. Amendments made by GL D-1 authorize the exportation, reexportation, or provision to Iran by U.S. persons located
outside of the United States of certain specified hardware and software items that are not subject to the EAR. See GL D-1 ,
paragraphs (a)(2)(ii) & (a)(3). GL D-1 also extends this authorization to an entity owned or controlled by a U.S. person and
established or maintained outside the United States (“a U.S.-owned or -controlled foreign entity”), subject to the conditions set
forth in 31 C.F.R. § 560.556. See GL D-1 , Note 2 to paragraph (a). Under these amendments, for example, an overseas
branch of a U.S. company or a U.S.-owned or -controlled foreign entity may export to Iran, from a location outside the United
States, certain hardware or software that is not subject to the EAR (including foreign-origin hardware or software containing
less than a de minimis amount of U.S. controlled content) if the hardware or software is within the scope of the GL D-1
authorization. These amendments also authorize the exportation, reexportation, or provision of certain fee-based software that
is not subject to the EAR because it is described in section 734.3(b) of the EAR. See FAQ #337. Section 734.3(b) of the EAR
describes “publicly available” software for purposes of those regulations. [02-07-2014]
343. Does GL D-1 authorize the exportation to Iran and importation into the United States of personal communication
devices by persons travelling from the United States to Iran and back to the United States?
Yes. As amended, GL D-1 authorizes both the exportation, reexportation, or provision to Iran and the importation into the
United States by an individual entering the United States directly or indirectly from Iran, of software authorized by 31 C.F.R. §
560.540 paragraph (a)(2) and software and hardware authorized by paragraphs (a)(2) and (a)(3) of GL D-1, provided that the
items were previously exported, reexported, or provided by the individual to Iran. See GL D-1 , paragraph (a)(5) and the
Note to paragraphs (a)(2) and (a)(3). See FAQ #337. [02-07-2014]
344. How do the authorizations in paragraphs (a)(1), (a)(2), and (a)(6) of GL D-1 compare to the previously existing
general license in 31 C.F.R. § 560.540 authorizing certain services and software incident to Internet-based
communications?
The general license in § 560.540 authorizes the exportation from the United States or by U.S. persons, wherever located, to
persons in Iran of no-cost services incident to the exchange of personal communications over the Internet and no-cost software
necessary to enable such services. Please also see OFAC’s Interpretive Guidance and Statement of Licensing Policy on
Internet Freedom in Iran (March 20, 2012). See http://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/internet_freedom.pdf. Paragraphs (a)(1) and (a)(2) of GL D-1 go beyond § 560.540
by, among other things, authorizing fee-based services and software incident to the exchange of personal communications
over the Internet.
In addition, to further ensure that the sanctions on Iran do not have an unintended chilling effect on the willingness of
companies to make available certain publicly available, no cost personal communications tools to persons in Iran, pursuant to
paragraph (a)(6) of GL D-1, the exportation, reexportation, or provision to the Government of Iran of certain publicly available,
no-cost services and software described in § 560.540(a) or categories (6) through (11) of the Annex to GL D-1 is authorized.
U.S. persons continue generally to be prohibited from exporting goods and services to persons whose property and interests in
property are blocked pursuant to any part of 31 C.F.R. chapter V, other than Government of Iran end-users blocked solely
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 34/50
pursuant to Executive Order 13599 . See GL D-1 paragraph (b)(2). Prohibited end-users include Iranian persons whose
property and interests in property are blocked pursuant to OFAC authorities relating to WMD proliferation, terrorism, and
human rights abuses. In addition, GL D-1 does not authorize any action or activity involving any item (including information)
subject to Commerce's Export Administration Regulations (EAR) that is prohibited by, or otherwise requires a license under,
part 774 of the EAR or participation in any transaction involving a person whose export privileges have been denied pursuant
to part 764 or 766 of the EAR, without authorization from the Department of Commerce. [02-07-2014]
345. How can U.S. companies arrange for payment from Iran for exports authorized under GLD-1?
In general, the payment requirements under GL D-1 are the same as for all other general licenses under the Iranian
Transactions and Sanctions Regulations (“ITSR”). Section 560.516 of the ITSR authorizes U.S. depository institutions to
process transfers of funds to or from Iran, or for the direct or indirect benefit of persons in Iran or the Government of Iran, if the
transfer arises from, and is ordinarily incident and necessary to give effect to, an underlying transaction that has been
authorized by a specific or general license issued pursuant to the ITSR and does not involve debiting or crediting an Iranian
account. 31 C.F.R. § 560.516(a). [02-07-2014]
346. What kind of due diligence is required for the exportation of fee-based services, software, or hardware authorized
by GL D-1?
Due diligence programs should be tailored to the particular risks encountered by exporters. As a general matter, companies
selling fee-based services, software, or hardware authorized by GL D-1 should undertake reasonable, risk-based measures
designed to ensure that they do not export their products to persons whose property and interests in property are blocked
pursuant to any sanctions program administered by OFAC, regardless of whether the Government of Iran or other end-user
appears on OFAC’s list of Specially Designated Nationals and Blocked Persons (or any of OFAC's other sanctions lists). [02-
07-2014]
347. Are there any restrictions as to the use of the Farsi language in authorized advertising or software?
U.S. sanctions on Iran do not impose any restrictions as to the use of the Farsi language. [02-07-2014]
348. May U.S. persons employ agents in Iran to facilitate sales, create or fund a physical sales presence on the ground
in Iran, or utilize Iranian commercial marketing services in furtherance of exports authorized under GL D-1?
No. GL D-1 does not authorize the employment of persons in Iran to facilitate sales, the maintenance of a physical sales
presence in Iran, or the utilization of Iranian marketing services. However, certain copy-ready advertising materials are exempt
from the prohibitions of the ITSR to the extent they qualify as information or informational materials pursuant to 31 C.F.R. §
560.210(c). [02-07-2014]
Specific Software, Hardware, and Services Covered by General License D-1 for Iran
For additional information regarding specific software, hardware, and services in Iran, please see the following topic.
Payments or the Facilitation of Payments to Iranian Civil Aviation Authorities for Overflights of Iran or Landing in Iran
Print this topic
417. Are payments or the facilitation of payments not involving U.S. persons to Iranian civil aviation authorities for
overflights of Iran or landing in Iran by aircraft that are owned by a non-U.S. person and registered outside the United
States sanctionable under U.S. law?
No. Provided that the relevant transactions do not involve the U.S. financial system or persons on the Specially Designated
Nationals and Blocked Persons List (SDN List), payments of charges for services rendered by the Government of Iran in
connection with the overflight of Iran or landing in Iran of aircraft owned by a non-U.S. person and registered outside the United
States are not subject to sanctions under U.S. law. The involvement of persons on the SDN List, including Iranian financial
institutions or airlines designated pursuant to Executive Order 13224 or Executive Order 13382 , would create sanctions
exposure for participants to such transactions.
U.S. persons and U.S.-owned or -controlled foreign entities cannot participate in transactions related to the payment of
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 35/50
overflight or landing fees to the Government of Iran, nor can such transactions transit the U.S. financial system, unless the
transactions fall within the scope of 31 C.F.R. § 560.522 or a specific license issued by OFAC and the payments in connection
with such authorized transactions are consistent with 31 C.F.R. § 560.516. [11-05-2018]
Provision of Routine Goods and Services by non-U.S. persons to Diplomatic Missions of the Government of Iran
Print this topic
455. Is the provision of routine goods and services by non-U.S. persons to diplomatic missions of the Government of
Iran located outside the United States sanctionable under U.S. law?
The provision of goods and services for the conduct of the official business of the diplomatic missions of the Government of
Iran located outside the United States or for the personal use of the employees of the missions, including financial services
such as the opening of a bank account, by a non-U.S. person would not be sanctionable under U.S. law, provided that such
goods and services do not involve persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (other than
any political subdivision, agency, or instrumentality of the Government of Iran listed solely pursuant to Executive Order
13599 or any Iranian depository institution listed solely pursuant to Executory Order 13599) or other activities that would be
sanctionable under U.S. law.
Further, the provision of goods and services to the diplomatic missions of the Government of Iran outside the United States
cannot involve U.S. persons or U.S.-owned or -controlled foreign entities, or the provision to the Government of Iran of goods,
technology, or services subject to the prohibitions of 31 C.F.R. §§ 560.204-205, nor can related transactions transit the U.S.
financial system, unless the activities and/or transactions are authorized by OFAC. [10-22-2015]
Additional Iran-related Questions From Financial Institutions
Print this topic
37. My bank operates accounts for individuals living in Iran. OFAC has told us that these accounts cannot be
operated. Does this mean that the accounts are blocked?
No, the accounts are restricted. The Iranian sanctions prohibit the export of goods or services to Iran. By operating an account
for an individual or company in Iran, the bank would be exporting services to that person or entity in violation of the Iranian
Transactions Regulations. The accounts, however, are not blocked. The account holder can close the account and have the
funds transferred to his or her account outside the United States. [09-10-02]
38. Are U-Turn payments for Iran still permitted?
No, as of November 10, 2008 U-Turn payments are no longer allowed. [11-10-08]
118. I have a client that is in Iran to visit a relative. Do I need to restrict the account?
No. As long as you are satisfied that the client is not ordinarily resident in IRAN, then the account does not need to be
restricted. [07-28-09]
54. I have an account with a W-8 showing an address in Iran. Is the account automatically restricted?
In the absence of information proving to your satisfaction that the account holder is not in Iran, you should consider the account
restricted based on the W-8 filing. [06-24-05]
Countering America’s Adversaries Through Sanctions Act (CAATSA) Section 105
Print this topic
533. What are the requirements of CAATSA section 105 related to the imposition of sanctions on the IRGC, and how
are those requirements being implemented?
On August 2, 2017, the President signed into law the “Countering America’s Adversaries Through Sanctions Act” (Public Law
115-44) (CAATSA ), which, among other things, imposes new sanctions on Iran. Section 105 of CAATSA requires the
imposition of sanctions applicable pursuant to the global terrorism Executive Order 13224 on Iran’s Islamic Revolutionary
Guard Corps (IRGC) and foreign persons that are officials, agents, or affiliates of the IRGC. Consistent with that requirement of
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 36/50
CAATSA, OFAC designated the IRGC on October 13, 2017, pursuant to E.O. 13224 for providing support to the IRGC-Qods
Force, which previously had been designated for its support to various terrorist groups. In addition, effective October 31, 2017,
OFAC amended the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594, to block the property and interests in property
of foreign persons that have been identified by OFAC as officials, agents, or affiliates of the IRGC. [10/30/2017]
534. Before October 13, 2017, wasn’t the IRGC already subject to sanctions? What’s different about applying
terrorism-related sanctions to the IRGC and foreign persons that are officials, agents, or affiliates of the IRGC?
Before October 13, 2017, the IRGC was blocked under Executive Order 13382 (relating to WMD proliferation), 13553
(relating to Iranian human rights abuses), and 13606 (relating to Iranian and Syrian human rights abuses via information
technology), and persons who engaged in certain activity involving the IRGC were already subject to secondary sanctions.
OFAC’s October 13, 2017 action designating the IRGC under E.O. 13224 (relating to counterterrorism) and OFAC’s
October 31, 2017 action under the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR), to block the property
and interests in property of foreign persons that have been identified by OFAC as officials, agents, or affiliates of the IRGC
carry additional consequences that limit certain activities with respect to the IRGC and foreign persons identified by OFAC as
officials, agents, or affiliates of the IRGC. Certain exemptions available under the International Emergency Economic Powers
Act (IEEPA) relating to personal communications, humanitarian donations, information or informational materials, and travel
do not apply to transactions with persons designated under E.O. 13224 or otherwise blocked pursuant to the GTSR, which
include the IRGC and foreign persons that have been identified by OFAC as officials, agents, or affiliates of the IRGC.
[10/30/2017]
535. Is the IRGC now a Foreign Terrorist Organization (FTO)?
No. The Department of State has not designated the IRGC as an FTO. [10/13/2017]
Guidance Related to Humanitarian Assistance with Regard to the November
12, 2017 Earthquake in Iran
Print this topic
549. In light of the recent earthquake in Iran, how can I help the Iranian people while making sure to abide by U.S.
sanctions?
In light of the tragic earthquake in Iran, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) would like to
highlight some of the ways in which Americans can provide humanitarian assistance to the Iranian people, consistent with the
Iran-related sanctions administered by OFAC.
General License E , issued by OFAC in 2013 pursuant to the Iranian Transactions and Sanctions Regulations, 31 C.F.R.
part 560 (ITSR), authorizes nongovernmental organizations to export services to Iran in support of activities related to
humanitarian projects to meet basic human needs in Iran, including the provision of relief services related to natural disasters,
the provision of donated health-related services, and the distribution of donated articles (such as food, clothing, and medicine)
intended to be used to relieve human suffering in Iran. In addition, nongovernmental organizations are authorized to transfer
up to $500,000 per year in support of these activities, subject to certain conditions, including reporting requirements.
U.S. individuals may raise funds outside of Iran in support of relief services provided by nongovernmental organizations
pursuant to General License E , and may make financial donations to such nongovernmental organizations in support of
authorized activities. General License E does not, however, authorize U.S. individuals to transfer financial donations directly to
Iran or nongovernmental organizations in Iran or to organize disaster relief services in Iran such as fire, rescue, or medical
services. U.S. persons interested in doing so should consider working through a nongovernmental organization in order to
conduct such activity.
In addition, donations of articles such as food, clothing, and medicine intended to be used to relieve human suffering are
exempt from the sanctions on trade between the United States and Iran, as long as the donations are not being sent to the
Government of Iran or any Iranian individual or entity on the List of Specially Designated Nationals and Blocked Persons (SDN
List).
Finally, U.S. financial institutions are authorized to process noncommercial, personal remittances to Iran, which may include a
personal transfer of funds from the United States to Iran to assist a friend or family member, provided that the transfer complies
with the requirements of sections 560.516 and 560.550 of the ITSR. [11-17-2017]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 37/50
Frequently Asked Questions Regarding Executive Order of August 6, 2018,
“Reimposing Certain Sanctions With Respect to Iran”
Print this topic
597. What is the purpose of Executive Order (E.O) of August 6, 2018, “Reimposing Certain Sanctions With Respect to
Iran”?
In accordance with his May 8, 2018 decision to cease the United States’ participation in the Joint Comprehensive Plan of
Action (JCPOA) and to reimpose all of the U.S. sanctions lifted or waived in connection with the JCPOA, the President issued
E.O. 13846 on August 6, 2018 to reimpose relevant provisions of E.O. 13574 of May 23, 2011; E.O. 13590 of November 20,
2011; E.O. 13622 of July 30, 2012; and E.O. 13645 of June 3, 2013, that had been revoked by E.O. 13716 of January 16,
2016. Consistent with guidance issued by the Department of the Treasury on May 8, 2018 , E.O. 13846 reimposes
specified sanctions relating to Iran following relevant wind-down periods, i.e., on or after August 7, 2018 or November 5, 2018,
depending on the activity involved. In addition, to provide clarity and consolidate relevant authorities into a single E.O., E.O.
13846 revokes E.O.s 13716 and 13628 and continues in effect sanctions authorities provided for in those E.O.s. E.O. 13846
also broadens the scope of certain provisions contained in those E.O.s, as outlined in FAQ 601 below. [08-06-2018]
598. What does E.O. 13846 do?
E.O. 13846 reimposes relevant blocking sanctions, correspondent and payable-through account sanctions, and menubased
sanctions previously provided for in E.O.s 13574, 13590, 13622, and 13645, which were revoked by E.O. 13716, and
continues in effect sanctions authorities provided for in E.O.s 13628 and 13716. As incorporated into E.O. 13846, these
measures include implementing authority for and additional tools related to: the Iran Sanctions Act of 1996, as amended
(ISA) , the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010, as amended (CISADA) , the Iran
Threat Reduction and Syria Human Rights Act of 2012 (TRA) , and the Iran Freedom Counter-Proliferation Act of 2012
(IFCA) (see FAQ 605). As a general matter, E.O. 13846 incorporates exceptions to these sanctions, including for
transactions for the provision of agricultural commodities, food, medicine, or medical devices to Iran, to the same extent such
exceptions applied under the prior E.O.s. E.O. 13846 also broadens the scope of certain provisions contained in those E.O.s,
as outlined in FAQ 601 below.
Section 1 of E.O. 13846 authorizes blocking sanctions on persons determined:
i. On or after August 7, 2018, to have provided material support for, or goods or services in support of, the purchase or
acquisition of U.S. bank notes or precious metals by the Government of Iran (GOI) (subsection 1(a)(i));
ii. On or after November 5, 2018, to have provided material support for, or goods or services in support of, the National
Iranian Oil Company (NIOC), the Naftiran Intertrade Company (NICO), or the Central Bank of Iran (CBI) (subsection 1(a)
(ii));
iii. On or after November 5, 2018, to have provided material support for, or goods or services in support of:
a. Any Iranian person on the List of Specially Designated Nationals and Blocked Persons (SDN List) (other than an
Iranian depository institution whose property and interests in property are blocked solely pursuant to E.O. 13599)
(subsection 1(a)(iii)(A)); or
b. Any other person on the SDN List whose property and interests in property are blocked pursuant to subsection
1(a) of E.O. 13846 or E.O. 13599 (other than an Iranian depository institution whose property and interests in
property are blocked solely pursuant to E.O. 13599) (subsection 1(a)(iii)(B)); or
iv. Pursuant to the relevant statutory authorities in IFCA, to be:
a. Part of Iran’s energy, shipping, or shipbuilding sectors (subsection 1(a)(iv)(A));
b. A port operator in Iran (subsection 1(a)(iv)(B)); or
c. A person that knowingly provides significant support to a person determined to be part of Iran’s energy, shipping,
or shipbuilding sectors, a port operator in Iran, or an Iranian person included on the SDN List (other than a person
described in section 1244(c)(3) of IFCA)) (subsection 1(a)(iv)(C)).
Section 2 of E.O. 13846 authorizes correspondent and payable-through account sanctions on foreign financial institutions
(FFIs) determined to have knowingly conducted or facilitated any significant financial transaction:
i. On or after August 7, 2018, for the sale, supply, or transfer to Iran of significant goods or services used in connection with
Iran’s automotive sector (subsection 2(a)(i));
ii. On or after November 5, 2018, on behalf of an Iranian person on SDN List (other than an Iranian depository institution whose
property and interests in property are blocked solely pursuant to E.O. 13599) or any other person on the SDN List whose
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 38/50
property is blocked pursuant to subsection 1(a) of E.O. 13846 or E.O. 13599 (other than an Iranian depository institution whose
property and interests in property are blocked solely pursuant to E.O. 13599) (subsection 2(a)(ii));
iii. On or after November 5, 2018, with NIOC or NICO, except for the sale or provision to NIOC or NICO of the products
described in section 5(a)(3)(A)(i) of ISA provided that the fair market value of such products is lower than the applicable dollar
threshold specified in that provision (subsection 2(a)(iii));
iv. On or after November 5, 2018, for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum
products from Iran (subsection 2(a)(iv)); and
v. On or after November 5, 2018, for the purchase, acquisition, sale, transport, or marketing of petrochemical products from
Iran (subsection 2(a)(v)).
Section 3 of E.O. 13846 authorizes menu-based sanctions on persons determined to:
i. Have knowingly engaged, on or after August 7, 2018, in a significant transaction for the sale, supply, or transfer to Iran of
significant goods or services used in connection with Iran’s automotive sector (subsection 3(a)(i));
ii. Have knowingly engaged, on or after November 5, 2018, in a significant transaction for the purchase, acquisition, sale,
transport, or marketing of petroleum or petroleum products from Iran (subsection 3(a)(ii));
iii. Have knowingly engaged, on or after November 5, 2018, in a significant transaction for the purchase, acquisition, sale,
transport, or marketing of petrochemical products from Iran (subsection 3(a)(iii)); or
iv. Be a successor entity to a person determined to meet any of the criteria set out in subsections 3(a)(i)-(a)(iii) of E.O.
13846 (subsection 3(a)(iv)); or
v. Own or control a person determined to meet any of the criteria set out in subsections 3(a)(i)-(a)(iii) of E.O. 13846 and to have
had knowledge that the person engaged in the activities referred to in the relevant subsection (subsection 3(a)(v)); or
vi. Be owned or controlled by, or under common ownership or control with, a person determined to meet any of the criteria set
out in sections 3(a)(i)-3(a)(iii) of E.O. 13846, and knowingly engaged in the activities referred to in the relevant subsection
(subsection 3(a)(vi)).
Section 4 of E.O. 13846 provides authority for the heads of relevant agencies of the U.S. government to implement the menubased
sanctions provided for in section 3.
Section 5 of E.O. 13846 provides authority for the Treasury Department to implement the menu-based sanctions provided for in
ISA, CISADA, TRA, IFCA, and section 3 of E.O. 13846
Section 6 of E.O. 13846 authorizes correspondent or payable-through account sanctions or blocking sanctions on FFIs that are
determined to have, on or after August 7, 2018: (a) knowingly conducted or facilitated any significant transaction related to the
purchase or sale of Iranian rials or a derivative, swap, future, forward, or other similar contract whose value is based on the
exchange rate of the Iranian rial (subsection 6(a)(i)); or (b) maintained significant funds or accounts outside the territory of Iran
denominated in the Iranian rial (subsection 6(a)(ii)).
Section 7 of E.O. 13846 carries forward sections 2 and 3 of E.O. 13628 and subsection 3(c) of E.O. 13716 (see FAQ 602
below) by providing for blocking sanctions on persons determined to:
i. Have engaged, on or after January 2, 2013, in corruption or other activities relating to the diversion of goods, including
agricultural commodities, food, medicine, and medical devices, intended for the people of Iran (subsection 7(a)(i));
ii. Have engaged, on or after January 2, 2013, in corruption or other activities relating to the misappropriation of proceeds from
the sale or resale of goods described in subsection 7(a)(1) of E.O. 13846 (subsection 7(a)(ii));
iii. Have knowingly, on or after August 10, 2012, transferred or facilitated the transfer of, goods or technologies to Iran, any
entity organized under the laws of Iran, or otherwise subject to the jurisdiction of the GOI, or any national of Iran for use in or
with respect to Iran, that are likely to be used by the GOI or any of its agencies or instrumentalities, or by any person on behalf
of the GOI or any such agencies or instrumentalities, to commit serious human rights abuses against the people of Iran
(subsection 7(a)(iii));
iv. Have knowingly, on or after August 10, 2012, provided services, including services relating to hardware, software, or
specialized information or professional consulting, engineering, or support services with respect to goods or technologies that
have been transferred to Iran and that are likely to be used by the GOI or any of its agencies or instrumentalities, or by any
person on behalf of the GOI or any such agencies or instrumentalities, to commit serious human rights abuses against the
people of Iran (subsection 7(a)(iv));
v. Have engaged in censorship or other activities with respect to Iran, on or after June 12, 2009, that prohibit, limit, or penalize
the exercise of freedom of expression or assembly by citizens of Iran, or that limit access to print or broadcast media, including
the facilitation or support of intentional frequency manipulation by the GOI or an entity owned or controlled by the GOI that
would jam or restrict an international signal (subsection 7(a)(v));
vi. Have materially assisted or provided other support for activities listed in subsections 7(a)(i)-(a)(v) of E.O. 13846 (subsection
7(a)(vi)); or
vii. Be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose
property and interests in property are blocked pursuant section 7 of E.O. 13846 (subsection 7(a)(vii)).
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 39/50
Section 8 of E.O. 13846 continues in effect the sanctions previously contained in section 4 of E.O. 13628, which prohibit an
entity owned or controlled by a U.S. person and established or maintained outside the United States (a “U.S.-owned or -
controlled foreign entity”) from knowingly engaging in any transaction, directly or indirectly, with the GOI or any person subject
to the jurisdiction of the GOI, if that transaction would be prohibited by specified authorities if engaged in by a U.S. person or in
the United States (see FAQs 621-623 below).
Section 9 of E.O. 13846 provides that it revokes and supersedes E.O.s 13628 and 13716 (see FAQ 602 below).
Sections 10-22 of E.O. 13846 contain exceptions, definitions, and other implementing provisions related to the sanctions in the
E.O. [08-06-2018]
599. When does E.O. 13846 become effective?
E.O. 13846 is effective at 12:01 a.m. eastern daylight time (EDT) on August 7, 2018. However, certain sanctions set out in
E.O. 13846 apply only to activities that take place on or after November 5, 2018, as set out in FAQ 598 above and in the
relevant provisions of E.O. 13846.
E.O. 13846 is being issued to coincide with the end of the 90-day wind down period which started on May 8, 2018 . The last
day of the 90-day wind-down period is August 6, 2018, and, as announced on May 8, 2018, certain sanctions previously lifted
under the JCPOA will be reimposed on August 7, 2018, including sanctions set out in E.O. 13846 (see FAQ 598 above). [08-
06-2018]
600. Why does subsection 1(a)(iv) of E.O. 13846 take effect before November 5, 2018?
Subsection 1(a)(iv) authorizes blocking sanctions pursuant to section 1244(c)(1)(A) of IFCA on persons determined to: (A) be
part of the energy, shipping, shipbuilding sectors of Iran; (B) operate a port in Iran; or (C) knowingly provide significant support
to certain other persons sanctioned pursuant to section 1244(c)(1)(A) of IFCA or an Iranian person on the SDN List. Consistent
with the guidance issued by the U.S. Department of the Treasury on May 8, 2018, the relevant sanctions in section 1244(c)(1)
(A) of IFCA are waived through November 4, 2018 to provide a wind-down period for activities involving Iran that were
consistent with the U.S. sanctions relief provided for under the JCPOA. However, the sanctions provided for in section 1244(c)
(1)(A) of IFCA targeting significant support to Iranian persons on the SDN List remained in effect even when the JCPOA
sanctions relief was in effect. To the extent activities within the scope of section 1244(c)(1)(A) of IFCA involve persons on the
SDN List or otherwise sanctionable conduct, persons engaging in such activities could be exposed to sanctions under
subsection 1(a)(iv) of E.O. 13846 prior to November 5, 2018. [08-06-2018]
601. Does E.O. 13846 expand the scope of sanctions that were in effect prior to January 16, 2016 (Implementation Day
of the JCPOA)?
Yes. E.O. 13846 broadens the scope of the sanctions that were in effect prior to January 16, 2016 and provides for greater
consistency in the administration of Iran-related sanctions provisions. These added measures are as follows:
i. Subsection 1(a)(iii)(B): Providing new authority for blocking sanctions on persons determined, on or after November 5, 2018,
to have provided material support for, or goods and services in support of, persons blocked for:
a. Providing material support for, or goods and services in support of, the purchase or acquisition of U.S. bank notes or
precious metals by the GOI (i.e., persons designated pursuant to subsection 1(a)(i));
b. Providing material support for, or goods and services in support of, NIOC, NICO, or CBI (i.e., persons designated pursuant to
subsection 1(a)(ii)); or
c. Being part of the energy, shipping, or shipbuilding sectors of Iran or a port operator in Iran or knowingly providing significant
support to certain other persons blocked pursuant to section 1244(c)(1)(A) of IFCA or to an Iranian person on the SDN List
(i.e., persons blocked pursuant to subsection 1(a)(iv) for meeting the criteria of section 1244(c)(1)(A) of IFCA).
ii. Subsection 2(a)(ii): Providing new authority for correspondent and payable-through account sanctions on FFIs determined to
have, on or after November 5, 2018, knowingly conducted or facilitated any significant financial transaction on behalf of the
persons blocked under the new authorities in subsection 1(a)(iii)(B) described above (i.e., any person blocked pursuant to
subsections 1(a)(i), 1(a)(ii), or 1(a)(iv) and included on the SDN List).
iii. Sections 4 and 5: Expanding the menu of sanctions available to impose on persons determined to have, on or after
November 5, 2018, knowingly engaged in certain significant transactions relating to petroleum, petroleum products, or
petrochemicals from Iran (i.e., persons determined to meet the criteria in subsections 3(a)(ii)-(a)(iii) or to be a derivative thereof
pursuant to subsections 3(a)(iv)-(a)(vi)) by authorizing the imposition of:
a. Visa restrictions on corporate officers, principals, or controlling shareholders of a sanctioned person (subsection (4)(e));
b. Any of the sanctions from the menu set forth in subsections 4(a)-(e) on principal executive officers of a sanctioned person
(subsection 4(f));
c. Prohibitions on U.S. persons investing in or purchasing significant amounts of equity or debt instruments of a sanctioned
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 40/50
person (subsection 5(a)(v)); or
d. Any of the sanctions from the menu set forth in subsections 5(a)(i)-(a)(vi) on principal executive officers of a sanctioned
person (subsection 5(a)(vii)).
iv. Section 8: Expanding the prohibition on U.S.-owned or -controlled foreign entities previously contained in section 4 of E.O.
13628 (see FAQs 621-623) by prohibiting transactions with persons blocked for:
a. Providing material support for, or goods and services in support of, Iranian persons on the SDN List and certain other
designated persons (i.e., persons designated pursuant to subsection 1(a)(iii)); or
b. Being part of the energy, shipping, or shipbuilding sectors of Iran or a port operator in Iran or knowingly providing significant
support to certain other persons blocked pursuant to section 1244(c)(1)(A) of IFCA or to an Iranian person on the SDN List
(i.e., persons blocked pursuant to subsection 1(a)(iv) for meeting the criteria of section 1244(c)(1)(A) of IFCA). [08-06-2018]
602. Why does E.O. 13846 revoke E.O. 13716 and E.O. 13628?
To provide clarity and consolidate relevant authorities into a single document, E.O. 13846 revokes E.O.s 13716 and 13628,
and continues in effect relevant provisions from those two revoked E.O.s. Provisions of E.O. 13846 that carry forward relevant
provisions of E.O.s 13628 and 13716 include:
• Section 7, which consolidates into a single section designation authorities targeting corruption or other activities relating to the
diversion of goods intended for the people of Iran, the transfer of goods or technologies to Iran that are likely to be used by the
GOI or any of its agencies or instrumentalities to commit serious human rights abuses against the people of Iran or the
provision of certain services with respect to such goods or technologies, and persons engaged censorship in Iran (these
provisions previously appeared in sections 2 and 3 of E.O. 13628 and section 8 of E.O. 13645, which was carried forward by
subsection 3(c) of E.O. 13716), and
• Section 8 extends certain prohibitions applicable to U.S. persons under OFAC-administered Iran sanctions to U.S.-owned or -
controlled foreign entities and provides for civil penalties on the U.S. parent for any violations of such prohibitions to the same
extent that they would apply to a U.S. person for the same conduct, consistent with section 218 of the TRA (this provision
was formerly contained in section 4 of E.O. 13628). [08-06-2018]
603. Do persons who were designated pursuant to E.O. 13628 of October 9, 2012, “Authorizing the Implementation of
Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 and Additional
Sanctions With Respect to Iran,” continue to be subject to sanctions following the issuance of E.O. 13846?
Yes. OFAC is taking action under section 7 of E.O. 13846 to continue in effect the designations of persons who were
designated pursuant to E.O. 13628 at the time of the issuance of E.O. 13846 U.S. persons must continue to block the property
and interests in property of these individuals and entities, and non-U.S. persons should be aware of the sanctions risk
associated with these persons. [08-06-2018]
604. Why do the sanctions set out in E.O.s 13574 and 13590 not appear in E.O. 13846?
The Treasury Department implementation authorities set out in section 1 of E.O. 13574 for “menu-based” sanctions under ISA
have been superseded by the implementation authorities for “menu-based” sanctions under a broader range of authorities that
include ISA , CISADA , TRA , and IFCA , and section 3 of E.O. 13846 As a result, section 1 of E.O. 13574 is not
included verbatim in E.O. 13846.
The sanctions set out in section 1 of E.O. 13590 — relating to development of petroleum resources in Iran and Iran’s domestic
production of petrochemical products — were incorporated into subsections 5(a)(5)-(a)(6) of ISA by a statutory amendment set
forth in section 201 of the TRA. As a result, the sanctions previously set forth in section 1 of E.O. 13590 are not included in
E.O. 13846, but remain in place pursuant to statutory authorities. Implementation authorities for the sanctions in subsections
5(a)(5)-(a)(6) of ISA are delegated to the appropriate agency heads through the Presidential Memorandum of October 9, 2012,
or through section 5 of E.O. 13846. [08-06-2018]
605. How does E.O. 13846 relate to various Iran-related statutes?
E.O. 13846 implements provisions of, and provides additional tools related to, ISA , CISADA , TRA , and IFCA
that were contained in the prior E.O.s. These include:
i. Invoking the President’s authority under the International Emergency Economic Powers Act (IEEPA) to supplement statutory
authorities in IFCA with prohibitions or restrictions on the importation of goods;
ii. Continuing to implement the statutory requirements of sections 105A and 105B of CISADA, as added by sections 402 and
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 41/50
403 of TRA, by providing authority to block the property and interests in property and suspend the entry into the United States
of persons determined to have engaged in the transfer of goods or technologies to Iran that are likely to be used by the GOI or
any of its agencies or instrumentalities to commit serious human rights abuses against the people of Iran or the provision of
services with respect to such goods or technology after they are transferred to Iran, and persons determined to have engaged
in censorship in Iran; and
iii. Continuing to implement the statutory requirements of section 105C of CISADA, as added by section 1249 of IFCA, by
providing authority to block the property and interests in property and suspend the entry into the United States of persons
determined to have engaged in corruption or other activities relating to the diversion of goods intended for the Iranian people or
the misappropriation of proceeds from the sale or resale of such goods. [08-06-2018]
606. What activity will become sanctionable on or after August 7, 2018 under E.O. 13846 or other authorities?
After the 90-day wind-down period ends on August 6, 2018, the following sanctions come into effect, including under provisions
of E.O. 13846 and relevant statutory authorities:
i. Sanctions on the purchase or acquisition of U.S. dollar banknotes by the GOI (see, e.g., subsection 1(a)(i) of E.O. 13846);
ii. Sanctions on Iran’s trade in gold or precious metals (see, e.g., subsection 1(a)(i) of E.O. 13846 and subsection 1245(a)(1)(A)
of IFCA );
iii. Sanctions on the direct or indirect sale, supply, or transfer to or from Iran of graphite, raw, or semi-finished metals such as
aluminum and steel, coal, and software for integrating industrial processes (see, e.g., section 5 of E.O. 13846 and subsections
1245(a)(1)(B)-(a)(1)(C) and (c) of IFCA);
iv. Sanctions on significant transactions related to the purchase or sale of Iranian rials, or the maintenance of significant funds
or accounts outside the territory of Iran denominated in the Iranian rial (see, e.g., section 6 of E.O. 13846);
v. Sanctions on the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt (see, e.g., section 5 of
E.O. 13846 and subsection 213(a) of TRA); and
vi. Sanctions on Iran’s automotive sector (see, e.g., subsections 2(a)(i) and 3(a)(i) of E.O. 13846). [08-06-2018]
607. What activity will become sanctionable on or after November 5, 2018 under E.O. 13846 or other authorities?
After the 180-day wind-down period ends on November 4, 2018, the following sanctions come into effect, including under
provisions of E.O. 13846 and relevant statutory authorities:
i. Sanctions on Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic of Iran Shipping
Lines (IRISL), South Shipping Line Iran, or their affiliates (see, e.g., subsection 1(a)(iv) and section 5 of E.O. 13846 and section
1244(c)(1) of IFCA);
ii. Sanctions on petroleum-related transactions with, among others, NIOC, NICO, and the National Iranian Tanker Company
(NITC), including the purchase of petroleum, petroleum products, or petrochemical products from Iran (see, e.g., subsections
1(a)(ii), 1(a)(iv), 2(a)(iii)-(a)(v), and 3(a)(ii)-(a)(iii) and sections 4 and 5 of E.O. 13846);
iii. Sanctions on transactions by FFIs with the CBI and designated Iranian financial institutions under section 1245 of the
National Defense Authorization Act for FY 2012 (NDAA 2012) (see, e.g., section 5 of E.O. 13846, section 1245 of NDAA 2012,
and subsection 1247(a) of IFCA);
iv. Sanctions on the provision of specialized financial messaging services to the CBI and Iranian financial institutions described
in subsection 104(c)(2)(E)(ii) of CISADA (see, e.g., section 5 of E.O. 13846, section 220 of TRA, and subsection 1244(c)(1) of
IFCA);
v. Sanctions on the provision of underwriting services, insurance, or reinsurance (see, e.g., section 5 of E.O. 13846, section
5(a)(7) of ISA, subsections 211(a) and 212(a) of TRA, and subsections 1246(a) and 1247(a) of IFCA); and
vi. Sanctions on Iran’s energy sector (see, e.g., subsection 1(a)(iv) and section 5 of E.O. 13846, subsection 5(a) of ISA, section
212(a) of TRA, and sections 1244(c)(1), (d) and (h)(2), 1246(a), and 1247(a) of IFCA). [08-06-2018]
Sanctions Relating to Transactions Involving the Iranian Rial
608. What transactions involving the Iranian rial are sanctionable under E.O. 13846?
Section 6 of E.O. 13846 reimposes the sanctions previously contained in section 1 of E.O. 13645 with respect to
transactions involving the Iranian rial. FFIs risk correspondent and payable-through account sanctions and blocking sanctions if
they, on or after August 7, 2018, (i) knowingly conduct or facilitate any significant transaction related to the purchase or sale of
Iranian rials or a derivative, swap, future, forward, or other similar contract whose value is based on the exchange rate of the
Iranian rial, or (ii) maintain significant funds or accounts outside the territory of Iran denominated in the Iranian rial. [08-06-
2018]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 42/50
Sanctions Relating to Iran’s Automotive Sector
609. What does E.O. 13846 do with respect to the sanctions on Iran’s automotive sector?
E.O. 13846 reimposes the sanctions previously contained in subsections 3(a)(ii) and section 5 of E.O. 13645 by authorizing
the imposition of correspondent and payable-through account sanctions (subsection 2(a)(i)) of E.O. 13846) and menu-based
sanctions (subsection 3(a)(i) of E.O. 13846) for certain transactions, on or after August 7, 2018, for the sale, supply, or transfer
to Iran of significant goods or services used in connection with Iran’s automotive sector. [08-06-2018]
610. What is considered Iran’s automotive sector for purposes of E.O. 13846?
E.O. 13846 defines the automotive sector of Iran as the manufacturing or assembling in Iran of light and heavy vehicles
including passenger cars, trucks, buses, minibuses, pick-up trucks, and motorcycles, as well as original equipment
manufacturing and after-market parts manufacturing relating to such vehicles. [08-06-2018]
611. What are goods or services used in connection with Iran’s automotive sector for purposes of E.O. 13846?
E.O. 13846 reimposes sanctions on certain transactions on or after August 7, 2018, for the sale, supply, or transfer to Iran
of “significant” goods or services used in connection with the automotive sector of Iran. (See FAQ 289 for an interpretation of
the term “significant.”)
We anticipate that forthcoming regulations will define “goods or services used in connection with the automotive sector of Iran”
to include goods or services that contribute to (i) Iran’s ability to research, develop, manufacture, and assemble light and heavy
vehicles, and (ii) the manufacturing or assembling of original equipment and after-market parts used in Iran’s automotive
industry. [08-06-2018]
612. Is the sale, supply, or transfer of finished vehicles or “auto kits” to Iran sanctionable under the New E.O.?
E.O. 13846 does not make sanctionable the export of finished vehicles to Iran if no further assembly or manufacturing is
required. As such, exporting fully assembled and finished vehicles to Iran for sale would not be sanctionable, so long as the
transaction is consistent with U.S. sanctions, including that it does not involve a sanctioned person.
In contrast, “auto kits” (or “knock-down kits”) exported to Iran for assembly in Iran would be considered goods or services used
in connection with the automotive sector of Iran and the export of such kits to Iran would be sanctionable if the transaction is
“significant.” (See FAQ 289 for an interpretation of the term “significant.”) [08-06-2018]
613. Is the sale, supply, or transfer of goods or services for the maintenance of finished vehicles sanctionable under
E.O. 13846?
Goods or services for the maintenance of finished vehicles exported to Iran would generally not be considered “significant
goods or services used in connection with the automotive sector of Iran” for the purposes of E.O. 13846 , and the provision
of such goods or services would generally not be sanctionable. However, the export, sale, or distribution of goods (e.g., auto
parts and accessories) or services that would contribute to Iran’s ability to manufacture or assemble vehicles, or manufacture
original equipment and after-market parts in Iran, could create exposure to sanctions. Persons exporting parts and services to
Iran for the maintenance or upkeep of finished automobiles, and FFIs facilitating such exports, should exercise caution to
ensure that the parts or services are not diverted for the manufacturing or assembly of vehicles in Iran or the manufacturing of
original equipment or after-market parts in Iran, and are used only for maintenance and upkeep. [08-06-2018]
Sanctions on Petroleum-related Transactions
614. What does E.O. 13846 do with respect to Iran’s energy, petroleum, and petrochemical sectors?
E.O. 13846 reimposes sanctions previously set out in E.O.s 13622, 13628, and 13645 with respect to the Iranian energy,
petroleum, and petrochemical sectors. As such, subsections 1(a)(ii) and (2)(a)(ii) of E.O. 13846 authorize blocking sanctions
and correspondent or payable-through account sanctions on persons providing material support for, or goods or services to,
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 43/50
NIOC or NICO. Separately, subsection 2(a)(iii) of E.O. 13846 authorizes the imposition of correspondent or payable-through
account sanctions on an FFI determined to have knowingly conducted or facilitated any significant financial transaction with
NIOC or NICO (except for sales of refined petroleum products to NIOC or NICO that are below the dollar threshold that could
trigger sanctions under section 5(a)(3)(A)(i) of ISA). Subsections 2(a)(iv)-(a)(v) provide authority to impose sanctions on FFIs
determined to have knowingly conducted or facilitated a significant transaction for the purchase, acquisition, sale, transport, or
marketing of petroleum, petroleum products, or petrochemicals from Iran, with the aim of deterring Iran or any other country or
institution from establishing workaround payment mechanisms for the purchase of Iranian oil to circumvent the NDAA 2012 oil
sanctions. Subsections 3(a)(ii)-(a)(iii) provide authority to impose menu-based sanctions or persons determined to have
engaged in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum
products from Iran. Furthermore, persons that sell, supply, or transfer to or from Iran significant goods or services used in
connection with Iran’s energy sector are exposed to menu-based sanctions pursuant to subsection 1244(d) of IFCA and
section 5 of E.O. 13846 The existing exception rules under NDAA 2012 apply to these sanctions. Thus, countries that are
determined by the Secretary of State to have significantly reduced their purchases of Iranian crude oil will be excepted from
these measures as well. (See FAQs 169-182 relating to the NDAA 2012 sanctions.)
The provisions in E.O. 13846 reimposing these sanctions come into effect beginning on November 5, 2018. [08-06-2018]
615. Does E.O. 13846 mean that Iran’s trade partners should no longer buy petroleum products from Iran? How will
this affect exports of Iranian oil?
These measures, which apply to transactions occurring on or after November 5, 2018, establish a key element of the
comprehensive Iran sanctions framework by deterring work-around financial transactions involving NIOC or NICO that were not
being captured under the sanctions previously implemented against the CBI at the time E.O. 13622 was issued. Iranian trade
partners can continue to buy petroleum and petroleum products from Iran without risking sanctions under E.O. 13846 if they
receive a significant reduction exception under relevant provisions of the NDAA 2012 for the relevant period. However, E.O.
13846 provides authority to sanction, on or after November 5, 2018, the purchase of petroleum or petroleum products and
significant dealings with NIOC or NICO by persons in jurisdictions that do not have a significant reduction exception. In
addition, IFCA provides for sanctions on persons determined to be part of the energy sector of Iran, or to sell, supply, or
transfer to or from Iran significant goods or services used in connection with the energy sector of Iran, provided the person is
not in a jurisdiction that has received a significant reduction exception. (See FAQs 293-297 relating to IFCA.) [08-06-2018]
616. Can countries that receive a significant reduction exception under NDAA 2012 purchase oil through NIOC and
NICO without facing sanctions?
All property and interests in property of NIOC and NICO subject to U.S. jurisdiction are already blocked pursuant to E.O.
13599 , and U.S. persons are prohibited from all dealings with these entities. E.O. 13846 reestablishes the authority
previously contained in E.O. 13622 to sanction FFIs that, on or after November 5, 2018, knowingly conduct or facilitate any
significant transaction with NIOC or NICO. Financial institutions in jurisdictions that have received a significant reduction
exception are not subject to these sanctions for transactions with NIOC and NICO for the purchase of petroleum or petroleum
products from Iran while the exception applies. In addition, IFCA provides for sanctions on persons that knowingly provide
significant financial, material, technological, or other support to, or goods or services in support of any activity or transaction on
behalf of or for the benefit of an Iranian person on the SDN List (other than non-designated Iranian financial institutions),
provided the person is not in a jurisdiction that has received a significant reduction exception. (See FAQs 293-297 relating to
IFCA.) [08-06-2018]
617. E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or
NICO subsidiary? Are transactions with those entities also sanctionable under this E.O.?
Yes. As in E.O. 13622, E.O. 13846 defines NIOC and NICO to include any entity owned or controlled by, or operating for or
on behalf of, NIOC and NICO. [08-06-2018]
618. Does E.O. 13846 make sanctionable activities related to the pipeline project to supply natural gas from the Shah
Deniz gas field in Azerbaijan to Europe and Turkey, given that NICO reportedly has a 10 percent stake in the project?
No. Section 10 of E.O. 13846 maintains the exceptions previously provided for in E.O. 13622 and E.O. 13645, as well as in
subsection 603(a) of the TRA and section 1254 of IFCA, for the pipeline project to supply natural gas from the Shah Deniz gas
field in Azerbaijan to Europe and Turkey. [08-06-2018]
619. Are barter arrangements or other non-cash trade transactions involving petroleum, petroleum products, or
petrochemical products originating from Iran sanctionable under the terms of E.O. 13846?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 44/50
Yes. To the extent a financial institution is involved, that financial institution could be sanctioned under E.O. 13846 for a
barter arrangement, on or after November 5, 2018, related to the purchase or acquisition of petroleum, petroleum products, or
petrochemical products from Iran. In addition, barter transactions knowingly conducted with NIOC, NICO, or the CBI also could
result in sanctions — regardless of whether a financial institution is involved — to the extent that those transactions constitute
material support for, or services to, NIOC, NICO, or the CBI. [08-06-2018]
620. What are the definitions of “petroleum products” and “petrochemical products”?
The term “petroleum products,” as defined in section 16(o) of E.O. 13846 , includes unfinished oils, liquefied petroleum
gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel
oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas,
and miscellaneous products obtained from the processing of: crude oil (including lease condensate), natural gas, and other
hydrocarbon compounds. The term does not include natural gas, liquefied natural gas, biofuels, methanol, and other nonpetroleum
fuels.
The term “petrochemical products,” as defined in section 16(m) of E.O. 13846, includes any aromatic, olefin, and synthesis
gas, and any of their derivatives, including ethylene, propylene, butadiene, benzene, toluene, xylene, ammonia, methanol, and
urea. [08-06-2018]
U.S.-owned or -controlled foreign entities
621. What is the prohibition on U.S.-owned or -controlled foreign entities, and how does it work?
Consistent with Section 218 of TRA , section 8 of E.O. 13846 continues in effect the sanctions previously contained in
section 4 of E.O. 13628 and expands them to cover activity sanctionable under E.O. 13846 (see FAQ 601). This provision
prohibits a U.S.-owned or -controlled foreign entity from knowingly engaging in any transaction, directly or indirectly, with the
GOI, or any person subject to the jurisdiction of the GOI, if that transaction would be prohibited by certain Executive orders
prohibiting trade and other dealings with, and investment in, Iran and blocking the GOI and Iranian financial institutions, or any
regulation issued pursuant to the foregoing (including the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560
(ITSR)), if the transaction were engaged in by a United States person or in the United States. Civil penalties for the U.S.-owned
or -controlled foreign entity’s violation of Section 8, attempted violation, conspiracy to violate, or causing of a violation shall
apply to the U.S. person that owns or controls such entity to the same extent that they would apply to a U.S. person for the
same conduct.
Section 20(c) of E.O. 13846 contains a savings clause that continues in effect under E.O. 13846 regulations, orders, directives,
and licenses that were issued pursuant to E.O. 13628 and remained in effect immediately prior to the date of E.O. 13846
Pursuant to this authority, section 560.215 of the ITSR, which implemented section 4 of 13628, and licenses issued pursuant to
E.O. 13628 that were valid as of the date of E.O. 13846 remain in effect, subject to their existing terms and conditions. Such
terms and conditions include the expiration date of the license. [08-06-2018]
622. Are U.S.-owned or -controlled foreign entities covered under OFAC general licenses and/or permitted to apply for
specific licenses from OFAC?
To the extent a transaction is exempt from the prohibitions of the ITSR, E.O. 13599 , or section 1 or 15 of E.O. 13846 , or
is authorized by a general license issued pursuant to these authorities if engaged in by a U.S. person, it would not be
prohibited for a U.S.-owned or -controlled foreign entity (as defined above) to engage in the transaction, provided that it
satisfies all the conditions and requirements of the exemption or general license. Similarly, if the transaction is one for which a
U.S. person might apply for a specific license — for example, under OFAC’s statement of licensing policy for certain targeted
educational, cultural, and sports exchange programs that are designed to directly benefit the Iranian people set forth at section
560.545 of the ITSR — a U.S.-owned or -controlled foreign entity or the U.S. person that owns or controls the entity may apply
for a specific license for the U.S.-owned or -controlled foreign entity to engage in the transaction. Note: whether a U.S. parent
company’s specific license covers transactions by its owned or controlled foreign entity that are otherwise prohibited by section
8 of E.O. 13846 will depend on the terms of that license and the scope of the authorized activities.
Pursuant to subsection 20(c) of E.O. 13846, section 560.556 of the ITSR, which extends general licenses available under the
ITSR to U.S.-owned or -controlled foreign entities, remains in effect. [08-06-2018]
623. Is there a wind-down or safe harbor provision for Section 8 of E.O. 13846?
No. Section 8 of E.O. 13846 continues in effect the prohibition previously contained in section 4 of E.O. 13628, which —
consistent with subsection 218(d) of the TRA — provided that civil penalties would not apply if a U.S. person that owns or
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 45/50
controls the foreign entity divested or terminated its business with the U.S.-owned or -controlled foreign entity not later than
February 6, 2013. Because the relevant prohibition came into effect more than five years ago and a wind-down period was
provided at that time, Section 8 of E.O. 13846 does not include such a wind-down authorization.
Please note, however, that section 560.537 of the ITSR authorizes — through 11:59 p.m. EST on November 4, 2018 — all
transactions and activities ordinarily incident and necessary to the wind down of activities that had been authorized under the
now-revoked Iran General License H. To the extent a U.S.-owned or -controlled foreign entity or a U.S. person is engaging in
wind-down activities pursuant to section 560.537 of the ITSR, those activities should be completed prior to the general license’s
expiration at 11:59 p.m. EST on November 4, 2018. [08-06-2018]
Sanctions Relating to the Provision of Material Assistance to Certain Persons
624. What are the implications of subsection 1(a)(iii) of E.O. 13846?
Subsection 1(a)(iii) of E.O. 13846 provides authority to block the property and interests in property of persons determined,
on or after November 5, 2018, to have materially assisted, sponsored, or provided financial, material, or technological support
for, or goods or services to or in support of: (A) Iranian persons included on the SDN List or (B) any other persons included on
the SDN List whose property and interests in property are blocked pursuant to Executive Order 13599 or subsection 1(a) of
E.O. 13846 (in both cases excluding Iranian depository institutions whose property and interests in property are blocked solely
pursuant to Executive Order 13599). Certain activities relating to the pipeline project to supply natural gas from the Shah Deniz
gas field in Azerbaijan to Europe and Turkey are excepted from this provision.
In implementing this provision, the United States Government will take appropriate steps to avoid, among other things, undue
impacts on the access of the people of Iran to humanitarian items, telecommunications, and other basic services. [08-06-18]
Frequently Asked Questions Related to the "Snap-back" of Iranian sanctions in November, 2018
630. Is the provision or delivery of goods or services to an Iranian counterparty after November 4, 2018 allowed?
The wind-down period has ended and the United States intends to fully enforce the sanctions that have come back into effect. The provision or delivery
of goods or services and/or the extension of additional loans or credits to an Iranian counterparty after November 4, 2018 — even pursuant to written
contracts or written agreements entered into prior to May 8, 2018 — may result in the imposition of U.S. sanctions unless such activities are exempt from
regulation, authorized by OFAC, or otherwise not sanctionable.
The United States maintains authorizations and exceptions under U.S. sanctions that allow for the sale of agricultural commodities, food, medicine, and
medical devices to Iran by U.S. persons and non-U.S. persons. However, these authorizations and exceptions do not apply to transactions involving
persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) that have been designated in connection with Iran’s support
for international terrorism or proliferation of weapons of mass destruction, including designated Iranian financial institutions or the Islamic Revolutionary
Guard Corps (IRGC), or activity that is subject to other sanctions (see FAQ 637). [11-05-2018]
631. I was not able to receive payment for goods or services fully provided or delivered prior to the end of the wind-down period. How should
I proceed?
In the event that a non-U.S., non-Iranian person is owed payment after the conclusion of the wind-down period on August 6, 2018, or November 4, 2018,
as applicable, for goods or services fully provided or delivered to an Iranian counterparty prior to August 6, 2018, or November 4, 2018, as applicable,
pursuant to a written contract or written agreement entered into prior to May 8, 2018, and such activities were consistent with U.S. sanctions in effect at
the time of delivery or provision, the U.S. government would allow the non-U.S., non-Iranian person to receive payment for those goods or services
according to the terms of the written contract or written agreement. Similarly, if a non-U.S., non-Iranian person is owed repayment after August 6, 2018,
or November 4, 2018, as applicable, for loans or credits extended to an Iranian counterparty prior to the end of the 90-day or 180- day wind-down period,
as applicable, provided that such loans or credits were extended pursuant to a written contract or written agreement entered into prior to May 8, 2018,
and such activities were consistent with U.S. sanctions in effect at the time the loans or credits were extended, the U.S. government would allow the
non-U.S., non-Iranian person to receive repayment of the related debt or obligation according to the terms of the written contract or written agreement.
This allowance is designed for non-U.S., non-Iranian parties to be made whole for debts and obligations owed or due to them for goods or services fully
provided or delivered or loans or credit extended to an Iranian party prior to the end of the 90-day or 180-day wind-down period, as applicable. Any
payments would need to be consistent with U.S. sanctions, including that payments could not involve U.S. persons or the U.S. financial system, unless
the transactions are exempt from regulation or authorized by OFAC (see FAQ 634 and FAQ 636).
The U.S. government would evaluate matters falling outside the above parameters on a case-by-case basis. [11-05-2018]
632. Will the U.S. government provide assurances beyond the guidance described in 631 and 634 that receipt of payment by non-U.S., non-
Iranian persons is not sanctionable?
OFAC encourages non-U.S., non-Iranian persons to rely on the guidance provided in FAQs 631 and 634. Non-U.S., non-Iranian persons can seek
guidance from OFAC or the State Department, as appropriate, prior to the receipt of payment, if they would like to confirm that the payments would meet
the criteria set forth in FAQ 631 and FAQ 634 and would not be subject to U.S. sanctions. [11-05-2018]
633. Under what circumstances are goods or services considered “fully provided or delivered” prior to the expiration of the relevant winddown
period, as referenced in FAQ 631 above?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 46/50
OFAC looks to the industry standard to determine whether particular goods or services are considered fully provided or delivered prior to the expiration
of the relevant wind-down period. As a general matter, goods or services will be considered fully provided or delivered when the party providing or
delivering the goods or services has performed all the actions and satisfied all the obligations necessary to be eligible for payment or other agreed-to
compensation. With respect to goods exported to or from Iran, at a minimum, title to the goods must have transferred to the relevant party. [08-06-2018]
634. Can I, as a non-U.S., non-Iranian person, receive payments after the relevant wind-down period ends for goods or services that were fully
provided or delivered during the relevant wind-down period pursuant to contracts entered into prior to May 8, 2018?
Yes, subject to the conditions set out below and in FAQ 631 above, non-U.S., non-Iranian persons may receive payment after the end of the relevant
wind-down period for goods or services fully provided or delivered to an Iranian counterparty prior to expiration of the relevant wind-down period (see
FAQ 633 above). In particular, the goods or services must have been fully provided or delivered prior to the end of the applicable wind-down period
pursuant to a written contract or written agreement entered into prior to May 8, 2018; the relevant activities must have been consistent with U.S.
sanctions in effect at the time of delivery or provision, including that the activities did not involve persons on the SDN List at the time of the transaction;
and any payments must be consistent with U.S. sanctions, including that payments can not involve U.S. persons or the U.S. financial system, unless the
transactions are exempt from regulation or authorized by OFAC (see FAQ 631 and FAQ 636). [11-05-2018]
635. Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive payments after the relevant wind-down period ends for goods
or services that were fully provided or delivered during the relevant wind-down period under an OFAC wind-down authorization and pursuant
to a contract entered into prior to May 8, 2018?
The wind-down authorizations allow U.S. persons and U.S.-owned or -controlled foreign entities to receive payments for activities conducted pursuant to
such wind-down authorizations only during their validity periods. For example, a U.S.-owned or -controlled foreign entity may receive payment through
11:59 p.m. eastern standard time on November 4, 2018 for Iran-related activities undertaken pursuant to section 560.537 of the Iranian Transactions and
Sanctions Regulations (ITSR) (winding down of transactions relating to U.S.-owned or -controlled foreign entities).
Any payment following the end of the relevant wind-down period for activities undertaken pursuant to a wind-down authorization, including from an
Iranian counterparty, would require specific authorization from OFAC. OFAC will evaluate such requests for specific licenses on a case-by-case basis.
Any request for a specific license should provide sufficient details for OFAC to evaluate the application, including: whether the relevant transactions
complied with U.S. sanctions as in effect at the time of the transactions; whether the activities were performed under a written contract or written
agreement entered into prior to May 8, 2018; and why the applicant was unable to receive the payment for which authorization is sought prior to the end
of the relevant wind-down period. OFAC will generally deny requests to receive payment for activities that were not authorized under the relevant winddown
authorizations or that were not undertaken pursuant to a written contract or written agreement entered into prior to May 8, 2018.
As required by 31 C.F.R. section 501.801(b), applicants should identify the names of all parties who are concerned with or interested in the proposed
transaction. To facilitate OFAC’s review, the request should also include a description of the efforts that were undertaken to collect the payment during
the relevant wind-down period and be accompanied by supporting documentation, including relevant contracts, invoices, and shipping documents.
OFAC encourages applicants to submit applications online (link available here). [11-05-2018]
636. Can I receive payment for activities undertaken during the wind-down period if the payment involves a person that has been added to the
SDN List, including a person that was previously on the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) but is
now designated under another authority?
The United States intends to fully enforce the sanctions that apply to persons that were previously on the E.O. 13599 List but that are now designated
under another authority.
U.S. persons and U.S.-owned or -controlled foreign entities generally would require an OFAC authorization to receive any payment involving an SDN,
regardless of whether they were previously on the E.O.13599 List. OFAC will evaluate requests for such authorization on a case-by-case basis,
including whether payments are for goods or services fully provided or delivered during the wind-down period pursuant to an OFAC wind-down
authorization (see FAQ 635).
Non-U.S. persons, including foreign financial institutions, could be subject to sanctions for knowingly engaging in certain significant transactions
involving an Iranian person on the SDN List – other than a non-designated Iranian financial institution – or a person designated in connection with Iran’s
support for international terrorism or proliferation of weapons of mass destruction, including a person that was previously on the E.O. 13599 List but is
now designated under another authority. Such persons will have a notation of “Additional Sanctions Information – Subject to Secondary Sanctions” in
their SDN List entry in addition to the tag for the other sanctions program(s) (e.g., the “[SDGT]” tag, the “[IRAN-HR]” tag, or the “[NPWMD]” tag for
persons designated under E.O. 13224, E.O. 13553, or E.O. 13382).
Non-U.S., non-Iranian persons seeking to receive payment for activities undertaken during the wind-down period that involves a person added to the
SDN List should seek guidance from OFAC or the State Department, as appropriate (see FAQ 634). [11-05-2018]
637. Is it sanctionable for non-U.S., non-Iranian persons to engage in transactions related to the provision of humanitarian and consumer
goods to Iran?
The United States maintains broad authorizations and exceptions under U.S. sanctions that allow for the sale of agricultural commodities, food,
medicine, and medical devices to Iran from the United States or by U.S. persons or U.S.-owned or -controlled foreign entities. U.S. sanctions laws
provide similar allowances for sales of food, agricultural commodities, medicine, and medical devices to Iran by non-U.S. persons. Broadly speaking,
transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran are not sanctionable unless they involve persons on the
SDN List that have been designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, including
designated Iranian financial institutions or the Islamic Revolutionary Guard Corps (IRGC), or activity that is subject to other sanctions. Additional
guidance relating to these authorizations and exceptions can be found on the OFAC website here and here .
Transactions by non-U.S. persons related to the export to Iran of consumer goods that do not fall within these exceptions, but are not expressly targeted
by U.S. sanctions, should not involve certain persons on the SDN List, including the Central Bank of Iran or a designated Iranian financial institution,
unless an exception under Section 1245(d)(4)(D) of the National Defense Authorization Act of Fiscal Year 2012 (NDAA 2012) applies, or the IRGC. In
addition, such transactions should not involve U.S. persons or transit the U.S. financial system, unless the activities and/or transactions are exempt from
regulation or authorized by OFAC. [11-05-2018]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 47/50
638. What happened to the E.O. 13599 List?
The E.O. 13599 List was created to clarify that, regardless of their removal from the SDN List on January 16, 2016, persons that OFAC had previously
identified as meeting the definition of the terms “Government of Iran” or “Iranian financial institution” still met those definitions and continued to be
persons whose property and interests in property were blocked pursuant to E.O. 13599 and section 560.211 of the ITSR. On November 5, 2018, OFAC
moved persons identified on the E.O. 13599 List to the SDN List and removed the E.O. 13599 List from its website.
Beginning on November 5, 2018, significant transactions with persons moved from the E.O. 13599 List to the SDN List, other than non-designated
Iranian financial institutions, could be subject to secondary sanctions, unless an exception applies, such as the exception relating to transactions for the
sale of agricultural commodities, food, medicine, or medical devices to Iran; or the significant reduction exception under Section 1245(d)(4)(D) of the
NDAA 2012. Persons subject to secondary sanctions will have a notation of “Additional Sanctions Information – Subject to Secondary Sanctions” in the
SDN List entry. In addition, effective November 5, 2018, OFAC has amended the ITSR to replace references to the E.O. 13599 List with references to
the SDN List.
Some persons moved to the SDN List from the E.O. 13599 List also have been designated under additional authorities and, therefore, have received
new unique identification numbers (UIDs) when added to the SDN List. Users of OFAC’s sanctions list data may wish to reference the following mapping
table to see how these specific records were added back onto the SDN list. [11-05-2018]
639. Why are some persons that had been blocked solely pursuant to E.O. 13599 now designated pursuant to other authorities, such as E.O.
13224 and E.O. 13382?
OFAC designated multiple Iranian financial institutions and other persons previously blocked solely pursuant to E.O. 13599 under E.O. 13224 (relating to
counterterrorism), E.O. 13382 (relating to WMD proliferation), and E.O. 13553 (relating to serious human rights abuses by the Government of Iran) on
October 16, 2018, and November 5, 2018. These included persons that had been removed from the SDN List on January 16, 2016. As new information
became available, OFAC determined that these persons met one or more of the criteria for designation under OFAC’s other designation authorities.
Relatedly, a number of persons that were previously designated pursuant to E.O. 13382 and were removed from the SDN List on January 16, 2016 were
relisted on the SDN List on November 5, 2018 as persons identified as meeting the definitions of the “Government of Iran” or an “Iranian financial
institution” pursuant to E.O. 13599. [11-05-2018]
640. What does the November 5, 2018 amendment to the ITSR do?
This regulatory amendment does two things. First, it amends the ITSR to reflect the re-imposition of ITSR-related sanctions lifted under the JCPOA,
including sanctions pursuant to certain sections of E.O. 13846 and the relisting on the SDN List of persons included on the E.O. 13599 List. More
specifically, this rule reinstates the regulatory provisions implementing the blocking authorities that were previously in sections 5 and 6 of E.O. 13622 and
now are in sections 1 and 10 of E.O. 13846. Section 560.211(c) of the ITSR will now implement blocking of the property and interests in property of any
person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to have (i) on or after August 7, 2018, materially
assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, the purchase or acquisition of U.S.
bank notes or precious metals by the Government of Iran, or (ii) on or after November 5, 2018, materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services in support of, the National Iranian Oil Company (NIOC), the Naftiran Intertrade Company
(NICO), or the Central Bank of Iran. Additionally, this rule removes references to the E.O. 13599 List to reflect OFAC’s separate action removing the
E.O. 13599 List from its website and relisting on the SDN List the persons that were previously listed on the E.O. 13599 List.
Second, the rule amends an existing general license in the ITSR to allow individual U.S. persons to engage in transactions necessary to sell certain
personal property in Iran (which was acquired before becoming a U.S. person or which was inherited from persons in Iran) and to transfer the proceeds
of those sales to the United States. Section 560.543 of the ITSR currently authorizes individual U.S. persons to engage in transactions necessary for
the sale of real property in Iran and the transfer of related proceeds to the United States, subject to a number of conditions and limitations. Authorized
transactions include engaging the services of any persons in Iran necessary for the sale, such as an attorney, funds agent, or real estate broker,
provided such person is not a person whose property and interests in property are blocked pursuant to any part of 31 CFR chapter V, other than persons
whose property and interests in property are blocked solely pursuant to Executive Order 13599 as the Government of Iran. OFAC is amending section
560.543 of the ITSR to authorize the sale of personal property in Iran and the transfer of related proceeds to the United States, subject to the same
conditions and limitations applicable to sales of real property.
Section 560.543 of the ITSR, as amended, does not authorize transactions that would be prohibited by a different sanctions program administered by
OFAC, such as transactions with SDNs designated under E.O. 13224 or E.O. 13382 (OFAC’s counterterrorism or counterproliferation authorities). [11-
05-2018]
641. If a country with primary jurisdiction over a foreign financial institution did not receive a significant reduction exception (SRE) under
section 1245(d)(4)(D) of the NDAA 2012, can funds currently held at the foreign financial institution in that country on behalf of the Central
Bank of Iran be used to facilitate humanitarian trade with Iran?
Yes. Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran involving the Central Bank of Iran are excepted
from the relevant sanctions under section 1245(d)(2) of the NDAA 2012 and sections 561.203 and 561.204 of the Iranian Financial Sanctions
Regulations (31 C.F.R. Part 561) (IFSR), regardless of whether the country has received an SRE. In addition, funds held on behalf of a non-designated
Iranian financial institution at a foreign financial institution generally would not be subject to U.S. secondary sanctions and could be used to facilitate
humanitarian trade. [11-05-2018]
642. Is the provision of certain associated services relating to the purchase of petroleum or petroleum products from Iran by persons in a
country that has been granted a SRE sanctionable?
Many U.S. sanctions related to Iran include an exception for countries that have received a SRE under section 1245(d)(4)(D) of the NDAA 2012 (see
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… for additional information regarding the implementation of the
SRE and sanctionable transactions). To the extent the purchase of petroleum or petroleum products from Iran and the processing of the related financial
transactions meet the requirements set out in section 1245(d)(4)(D) of the NDAA 2012, the services used to import the petroleum from Iran including
services provided by the shipping sector of Iran and Iranian port operators would not be sanctionable pursuant to the Iran Freedom and Counter-
Proliferation Act of 2012 (IFCA), provided that Iranian entities that are involved in such transactions are not designated in connection with Iran’s support
for international terrorism, or its proliferation of weapons of mass destruction or their means of delivery. (see https://www.treasury.gov/resourcecenter/
faqs/Sanctions/Pages/faq_iran.aspx#ifca for additional information). [11-05-2018]
643. Is payment of Iran-related insurance or reinsurance claims made on or after November 5, 2018 sanctionable if the claim arises from an
incident that occurred prior to November 5, 2018?
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 48/50
Payment of Iran-related insurance or reinsurance claims arising from incidents that occurred prior to November 5, 2018 could create sanctions exposure
for non-U.S. persons to the extent such payment involves a person designated in connection with Iran’s proliferation of WMD or support for international
terrorism, or an Iranian person on the SDN List, other than a non-designated Iranian financial institution, or if the underlying activity involved such
persons or was otherwise sanctionable at the time it occurred.
U.S. persons continue to be generally prohibited under the ITSR from exporting goods, services, or technology directly or indirectly to Iran, including
participating in the payment of claims to or for the benefit of Iran or any persons blocked under the ITSR, or for the transportation of Iranian-origin oil,
unless exempt or specifically authorized by OFAC. In addition, after November 4, 2018, to the extent a claim payment involves a U.S.-owned or -
controlled foreign entity, the payment of such claim would be prohibited and would require an authorization from OFAC prior to payment.
See FAQ 102 and FAQ 103 for additional information relating to U.S. person involvement in global insurance policies and FAQ 303 and FAQ 304 for
additional information on secondary sanctions, and exceptions to these sanctions, such as the humanitarian exception, relating to insurance,
reinsurance, or underwriting activities relating to Iran. [11-05-2018]
644. Is an entity that is owned or controlled by a U.S. person and established or maintained outside the United States (a “U.S.-owned or -
controlled foreign entity”) required to apply restrictions akin to blocking on the property or interests in property of persons subject to section
560.211 of the ITSR?
Yes. Under section 560.215 of the ITSR, U.S.-owned or -controlled foreign entities are prohibited from knowingly engaging in any transaction, directly or
indirectly, with the Government of Iran or any person subject to the jurisdiction of the Government of Iran that would be prohibited by the ITSR if engaged
in by a U.S. person or in the United States. Section 560.211 of the ITSR separately prohibits transferring, paying, exporting, withdrawing, and dealing in
any property and interests in property of the Government of Iran, any Iranian financial institution, and any other persons whose property and interests in
property are blocked pursuant to the ITSR, unless exempt or authorized by OFAC.
In light of these prohibitions, U.S.-owned or -controlled foreign entities are required to apply restrictions akin to blocking on any property or interests in
property of persons subject to section 560.211 of the ITSR to ensure that such property and interests in property are not transferred, paid, exported,
withdrawn, or otherwise dealt in. This requirement applies both with respect to a person whose property and interests in property are blocked solely
pursuant to the ITSR and a person whose property and interests in property are blocked pursuant to the ITSR and another authority (e.g., when a
person is included on the List of Specially Designated Nationals and Blocked Persons with the “[IRAN]” tag, as well as a tag for another sanctions
program, such as the terrorism tag (“[SDGT]”), nuclear proliferation tag (“[NPWMD]”), or human rights tag (“[IRAN-TRA]” or “[IRAN-HR]”)).
Section 560.215(b)(1) of the ITSR deems an entity to be “owned or controlled” by a U.S. person if the U.S. person holds a 50 percent or greater equity
interest by vote or value in the entity; holds a majority of seats on the board of directors of the entity; or otherwise controls the actions, policies, or
personnel decisions of the entity. [11-05-2018]
645. How will the re-imposition of sanctions on November 5, 2018 impact the provision of specialized financial messaging services to Iranian
financial institutions?
Following the re-imposition of U.S. sanctions on November 5, 2018, sanctions that had previously been lifted or waived as part of U.S. commitments
under the Joint Comprehensive Plan of Action (JCPOA) will come back into effect in their entirety, including sanctions on the provision of specialized
financial messaging services to certain Iranian financial institutions.
As of November 5, 2018, sanctions on the provision of specialized financial messaging services set forth in section 220 of the Iran Threat Reduction and
Syria Human Rights Act of 2012 (TRA) snap back in full. This authority provides for sanctions on specialized financial messaging services to the Central
Bank of Iran or Iranian financial institutions designated in connection with Iran’s support for terrorism or its proliferation of weapons of mass destruction
(WMD) and WMD delivery systems, as set out in subsection 104(c)(2)(E)(ii) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of
2010 (CISADA) (see section 220 of the TRA). Such Iranian financial institutions are listed on the SDN List and carry the “[IFSR]” tag.
Furthermore, knowingly providing significant financial, material, technological, or other support to Iranian persons on the SDN List, other than Iranian
financial institutions blocked solely pursuant to E.O. 13599 and listed on the SDN List with only the “[IRAN]” tag, is sanctionable for persons in countries
that have not received a significant reduction exception (see subsection 1244(c)(1) of IFCA).
To avoid potential sanctions exposure, providers of specialized financial messaging services should discontinue the provision of such services to the
Central Bank of Iran and any Iranian financial institutions designated in connection with Iran’s WMD proliferation, support for terrorism, or human rights
abuses. The Central Bank of Iran and such designated Iranian financial institutions will have “Subject to Secondary Sanctions” listed in the
“Identifications” feature in their entry on the SDN List.
Given that the U.S. government will continue to apply maximum financial pressure on the Iranian regime, including potential additional designations of
Iranian financial institutions, the SDN List should be consulted regularly to determine which Iranian financial institutions have been designated. [11-05-
2018]
Frequently Asked Questions Regarding Executive Order (E.O.) “Imposing Sanctions with Respect to the Iron, Steel, Aluminum,
and Copper Sectors of Iran” of May 8, 2019
666. What does the Executive Order Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper
Sectors of Iran of May 8, 2019 do?
The Executive Order of May 8, 2019 authorizes sanctions with respect to the iron, steel, aluminum, and copper sectors of
Iran.
Section 1 of the E.O. of May 8, 2019 authorizes blocking sanctions on any person determined by the Secretary of the Treasury,
in consultation with the Secretary of State:
(i) to be operating in the iron, steel, aluminum, or copper sector of Iran, or to be a person that owns, controls, or operates an
entity that is part of the iron, steel, aluminum, or copper sector of Iran;
(ii) to have knowingly engaged, on or after the effective date of the order, in a significant transaction for the sale, supply, or
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 49/50
Return to the OFAC FAQ Index
transfer to Iran of significant goods or services used in connection with the iron, steel, aluminum, or copper sectors of Iran;
(iii) to have knowingly engaged, on or after the effective date of the order, in a significant transaction for the purchase,
acquisition, sale, transport, or marketing of iron, iron products, aluminum, aluminum products, steel, steel products, copper, or
copper products from Iran;
(iv) to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in
support of any person whose property and interests in property are blocked pursuant to section 1; or
(v) to be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose
property and interests in property are blocked pursuant to section 1.
Section 2 of the E.O. of May 8, 2019 authorizes correspondent and payable-through account sanctions on foreign financial
institutions (FFIs) determined to have knowingly conducted or facilitated any significant financial transaction:
(i) for the sale, supply, or transfer to Iran of significant goods or services used in connection with the iron, steel, aluminum, or
copper sectors of Iran;
(ii) for the purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminum, aluminum products, steel, steel
products, copper, or copper products from Iran; or
(iii) for or on behalf of any person whose property and interests in property are blocked pursuant to the order.
Sections 3-13 of the E.O. of May 8, 2019 contain exceptions, definitions, and other implementing provisions related to the
sanctions. [05-08-2019]
667. When does Executive Order Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors
of Iran become effective?
The E.O. of May 8, 2019 became effective upon signing. [05-08-2019]
668. Is there a wind-down period?
Yes. Persons engaged in transactions that could be sanctioned under the Executive Order Imposing Sanctions with
Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran of May 8, 2019 will have a 90-day period to wind down those
transactions without exposure to sanctions under the E.O. of May 8, 2019. Those persons should take the necessary steps to
wind down transactions by the end of the 90-day wind-down period to avoid exposure to sanctions. Entering into new business
that would be sanctionable under the E.O. of May 8, 2019 (the effective date of the E.O.) will not be considered wind-down
activity and could be sanctioned even during the wind-down period. [05-08-2019]
669. Does the Executive Order Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran expand upon existing sanctions
relating to trade with Iran in certain raw and semi-finished metals, such as aluminum and steel?
Yes. The E.O. of May 8, 2019 expands upon existing sanctions under section 1245 of IFCA on the sale, supply, or transfer, directly or indirectly, to or from Iran of
certain materials, including raw and semi-finished metals such as aluminum and steel, as described in subsections 1245(a)(l)(B) or (C) of IFCA.
In addition, the E.O. of May 8, 2019 explicitly targets the iron and copper sectors of Iran. [05-08-2019]
670. Are there exceptions to the sanctions imposed under E.O. of May 8, 2019?
Yes. The sanctions authorized under the E.O. of May 8, 2019 do not apply to transactions for the conduct of the official business of the United States Government or
the United Nations (including its specialized agencies, programmes, funds, and related organizations) by employees, grantees, or contractors thereof. [05-08-2019]
671. What is the definition of significant?
The Department of the Treasury anticipates adopting the interpretation of “significant” set out in 31 C.F.R § 561.404. See existing OFAC Iran FAQ 289. [05-08-2019]
Annex 151
8/5/2019 OFAC FAQs: Iran Sanctions
https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_iran… 50/50
Annex 151
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 1/83
U.S. DEPARTMENT OF THE TREASURY
Resource Center
Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons
List and 13599 List Removals
11/5/2018
OFFICE OF FOREIGN ASSETS CONTROL
Sanctions List Updates:
The following individuals have been added to OFAC's SDN List:
BAHADORI, Masoud; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Passport T12828814 (Iran); Managing
Director, Petro Suisse Intertrade Company (individual) [IRAN].
BATENI, Naser; DOB 16 Dec 1962; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [IRAN].
BAZARGAN, Farzad; DOB 03 Jun 1956; Additional Sanctions Information - Subject to Secondary Sanctions; Passport D14855558 (Iran); alt. Passport
Y21130717 (Iran); Managing Director, Hong Kong Intertrade Company (individual) [IRAN].
BEHZAD, Morteza Ahmadali (a.k.a. BEHZAD, Morteza; a.k.a. BEHZADI, Morteza); DOB 1959; alt. DOB 1960; POB Yazd, Iran; nationality Iran;
Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; National ID No. 4432151609 (Iran) (individual) [NPWMD] [IFSR]
(Linked To: PISHRO SYSTEMS RESEARCH COMPANY).
CAMBIS, Dimitris (a.k.a. KAMPIS, Dimitrios Alexandros; a.k.a. "KLIMT, Gustav"); DOB 14 Oct 1963; Additional Sanctions Information - Subject to
Secondary Sanctions (individual) [IRAN].
CHAGHAZARDY, Mohammad Kazem (a.k.a. CHAGHAZARDI, Mahammadkazem; a.k.a. CHAGHAZARDY, MohammadKazem); DOB 21 Jan 1962;
nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [NPWMD] [IFSR] (Linked To: BANK
SEPAH).
DAJMAR, Mohammad Hossein; DOB 19 Feb 1956; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [IRAN].
ESLAMI, Mansour; DOB 21 Jan 1965; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; Passport H37045909 (Iran)
(individual) [IRAN].
GHALEBANI, Ahmad (a.k.a. GHALEHBANI, Ahmad; a.k.a. QALEHBANI, Ahmad); DOB 01 Jan 1953 to 31 Dec 1954; Additional Sanctions Information -
Subject to Secondary Sanctions; Passport H20676140 (Iran); Managing Director, National Iranian Oil Company; Director, Hong Kong Intertrade
Company; Director, Petro Suisse Intertrade Company (individual) [IRAN].
JASHNSAZ, Seifollah (a.k.a. JASHN SAZ, Seifollah; a.k.a. JASHNSAZ, Seyfollah); DOB 22 Mar 1958; POB Behbahan, Iran; nationality Iran; Additional
Sanctions Information - Subject to Secondary Sanctions; Passport R17589399 (Iran); alt. Passport T23700825 (Iran); Chairman & Director, Naftiran
Intertrade Co. (NICO) Sarl; Chairman & Director, Naft Iran Intertrade Company Ltd.; Director, Hong Kong Intertrade Company; Chairman of the Board of
Directors, Iranian Oil Company (U.K.) Limited; Chairman & Director, Petro Suisse Intertrade Company (individual) [IRAN].
KHALILI, Jamshid; DOB 23 Sep 1957; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; Passport Y28308325 (Iran)
(individual) [IRAN].
KHOSROWTAJ, Mojtaba; DOB 09 Nov 1952; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; Passport D9016371
(Iran) (individual) [IRAN].
MOHADDES, Seyed Mahmoud; DOB 07 Jun 1957; citizen Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Managing Director,
Iranian Oil Company (U.K.) Ltd. (individual) [IRAN].
MOINIE, Mohammad; DOB 04 Jan 1956; POB Brojerd, Iran; citizen United Kingdom; Additional Sanctions Information - Subject to Secondary Sanctions;
Passport 301762718 (United Kingdom); Commercial Director, Naftiran Intertrade Company Sarl (individual) [IRAN].
NIKOUSOKHAN, Mahmoud; DOB 01 Jan 1961 to 31 Dec 1962; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions;
Passport U14624657 (Iran); Finance Director, National Iranian Oil Company; Director, Hong Kong Intertrade Company; Director, Petro Suisse Intertrade
Company (individual) [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 2/83
PARSAEI, Reza; DOB 09 Aug 1963; citizen Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Director, NIOC International Affairs
(London) Ltd. (individual) [IRAN].
POURANSARI, Hashem; nationality Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Passport B19488852 (Iran); Managing
Director, Asia Energy General Trading (individual) [IRAN].
REZVANIANZADEH, Mohammed Reza (a.k.a. REZVANIANZADE, Mohammad Reza; a.k.a. REZVANIANZADEH, Mohammad Reza; a.k.a.
REZVANYANZADEH, Mohammadreza); DOB 11 Dec 1969; POB Ardestan, Iran; Additional Sanctions Information - Subject to Secondary Sanctions;
Gender Male; Passport G10506469 (Iran) expires 12 Dec 2022 (individual) [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
SAEEDI, Mohammed; DOB 22 Nov 1962; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male; Passport W40899252 (Iran)
(individual) [IRAN].
SAFDARI, Seyed Jaber (a.k.a. SAFDARI, Sayyed Jaber; a.k.a. SAFDARI, Seyyed Jaber); DOB 1968 to 1969; Additional Sanctions Information - Subject
to Secondary Sanctions; Gender Male (individual) [IRAN] (Linked To: ADVANCED TECHNOLOGIES COMPANY OF IRAN).
SEYYEDI, Seyed Nasser Mohammad; DOB 21 Apr 1963; citizen Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Passport
B14354139 (Iran); alt. Passport L18507193 (Iran); alt. Passport X95321252 (Iran); Managing Director, Sima General Trading (individual) [IRAN].
SURI, Muhammad; DOB 01 Jan 1946 to 31 Dec 1946; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual)
[IRAN].
TABATABAEI, Seyyed Mohammad Ali Khatibi; DOB 27 Sep 1955; citizen Iran; Additional Sanctions Information - Subject to Secondary Sanctions;
Director, NIOC International Affairs (London) Ltd.; Director of International Affairs, NIOC (individual) [IRAN].
YAZDAN JOO, Mohammad Ali; DOB 03 Jun 1962; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual) [IRAN].
YOUSEFPOUR, Ali; DOB 01 Jan 1955 to 31 Dec 1955; Additional Sanctions Information - Subject to Secondary Sanctions; Gender Male (individual)
[IRAN].
ZIRACCHIAN ZADEH, Mahmoud; DOB 24 Jul 1959; citizen Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Director, Iranian Oil
Company (U.K.) Ltd. (individual) [IRAN].
The following entities have been added to OFAC's SDN List:
A.S.P. BUILDERS, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
AA ENERGY FZCO, United Arab Emirates; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
ADVANCED TECHNOLOGIES COMPANY OF IRAN (f.k.a. GHANI SAZI ENRICHMENT; f.k.a. IRANIAN ENRICHMENT COMPANY; a.k.a. "ADVANCED
TECHNOLOGIES"; a.k.a. "ADVANCED TECHNOLOGIES COMPANY"; a.k.a. "ADVANCED TECHNOLOGIES HOLDING COMPANY"; a.k.a. "IATC"),
Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
AEOI BASIJ RESISTANCE CENTER (a.k.a. BASIJ RESISTANCE CENTER OF THE AEOI), Iran; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
AGRICULTURAL, MEDICAL, AND INDUSTRIAL RESEARCH CENTER (a.k.a. KARAJ NUCLEAR RESEARCH CENTER FOR AGRICULTURE AND
MEDICINE; f.k.a. NUCLEAR RESEARCH CENTER FOR AGRICULTURE AND MEDICINE; a.k.a. "AMIRC"; f.k.a. "NRCAM"), Karaj, Iran; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NUCLEAR SCIENCE AND TECHNOLOGY RESEARCH INSTITUTE).
AMIN INVESTMENT BANK (a.k.a. AMINIB), No. 51 Ghobadiyan Street, Valiasr Street, Tehran 1968917173, Iran; Website http://www.aminib.com
[IRAN].
ARASH SHIPPING ENTERPRISES LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22678777) [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
ARIAN BANK, House 103, Shir Ali Khan Street, Charahi Torabaz Khan, District 10, Kabul, Afghanistan; Sherpoor, Hajj and religious affairs directorate
Square, Etisalat Street, Kabul, Afghanistan; Opposite of Attorney General, Hanzala Mosque Road, Shahre now, Kabul, Afghanistan; PO Box 5810,
Afghanistan; Ferdawsi Street (old telecommunication street), Between Alley 12 & 14, Herat, Afghanistan; SWIFT/BIC AFABAFKA; Website www.arianbank.
com.af; Additional Sanctions Information - Subject to Secondary Sanctions; All Offices Worldwide [SDGT] [IFSR] (Linked To: BANK MELLI IRAN).
ARJAN ELECTRICITY AND ENERGY GENERATION MANAGEMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN]
(Linked To: GHADIR INVESTMENT COMPANY).
ARMAN RESOURCES EQUIP AND SUPPORT MANAGEMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked
To: GHADIR INVESTMENT COMPANY).
ARTA SHIPPING ENTERPRISES LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22678777) [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 3/83
ASAN SHIPPING ENTERPRISE LIMITED, 85 St. John Street, Valletta VLT 1165, Malta; Additional Sanctions Information - Subject to Secondary
Sanctions; Telephone (356)(21241817); Fax (356)(25990640) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ASCOTEC HOLDING GMBH (f.k.a. AHWAZ STEEL COMMERCIAL & TECHNICAL SERVICE GMBH ASCOTEC; f.k.a. AHWAZ STEEL COMMERCIAL
AND TECHNICAL SERVICE GMBH ASCOTEC; a.k.a. ASCOTEC GMBH), Tersteegen Strasse 10, Dusseldorf 40474, Germany; Additional Sanctions
Information - Subject to Secondary Sanctions; Registration ID HRB 26136 (Germany); all offices worldwide [IRAN].
ASCOTEC JAPAN K.K., 8th Floor, Shiba East Building, 2-3-9 Shiba, Minato-ku, Tokyo 105-0014, Japan; Additional Sanctions Information - Subject to
Secondary Sanctions; all offices worldwide [IRAN].
ASCOTEC MINERAL & MACHINERY GMBH (a.k.a. ASCOTEC MINERAL AND MACHINERY GMBH; f.k.a. BREYELLER KALTBAND GMBH),
Tersteegenstr. 10, Dusseldorf 40474, Germany; Additional Sanctions Information - Subject to Secondary Sanctions; Registration ID HRB 55668
(Germany); all offices worldwide [IRAN].
ASCOTEC SCIENCE & TECHNOLOGY GMBH (a.k.a. ASCOTEC SCIENCE AND TECHNOLOGY GMBH), Tersteegenstrasse 10, Dusseldorf D 40474,
Germany; Additional Sanctions Information - Subject to Secondary Sanctions; Registration ID HRB 58745 (Germany); all offices worldwide [IRAN].
ASCOTEC STEEL TRADING GMBH (a.k.a. ASCOTEC STEEL), Tersteegenstr. 10, Dusseldorf 40474, Germany; Georg-Glock-Str. 3, Dusseldorf 40474,
Germany; Additional Sanctions Information - Subject to Secondary Sanctions; Registration ID HRB 48319 (Germany); all offices worldwide [IRAN].
ASIA ENERGY GENERAL TRADING (LLC), Suite 703, Twin Tower, Baniyas Street, Deira, Dubai, United Arab Emirates; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN].
ATIEH SAZAN DAY, No. 12, Taheri Street, Africa Blvd, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR]
(Linked To: DAY BANK).
ATLANTIC SHIPPING & TRANS (a.k.a. ATLANTIC SHIPPING AND TRANS; a.k.a. ATLANTIC SHIPPING AND TRANSPORTATION LIMITED), East
Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN]
(Linked To: NATIONAL IRANIAN TANKER COMPANY).
ATLAS KIAN QESHM (a.k.a. ATLAS SHIPPING; a.k.a. ATLAS SHIPPING COMPANY), No. 44, East Atefi Ave., Nelsonmandella Blvd., Tehran, Iran;
Website http://nitcshipping.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
ATOMIC ENERGY ORGANIZATION OF IRAN (a.k.a. AEOI), North kargar street, P.O. Box 14155-1339, Tehran, Iran; Website http://www.aeoi.org.ir;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
ATOMIC FUEL DEVELOPMENT ENGINEERING COMPANY (a.k.a. ENERGY NOVIN INDUSTRIAL DEVELOPMENT; a.k.a. MATSA COMPANY; a.k.a.
"ENID"; a.k.a. "MATSA"), Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY
ORGANIZATION OF IRAN).
AYANDEH BANK, Ayandeh Bank Bldg. Floor 1, 15 Shahid Ahmadian St. (15th St.) Ahmad Ghasir (Bucharest) Ave, Tehran, Iran; SWIFT/BIC AYBKIRTH;
Additional Sanctions Information - Subject to Secondary Sanctions; All Offices Worldwide [IRAN-TRA] (Linked To: ISLAMIC REPUBLIC OF IRAN
BROADCASTING).
AZAR INVESTMENT, Iran [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
AZAR PAD QESHM (a.k.a. AZARPAD QESHM; a.k.a. AZARPAD QESHM CO; a.k.a. "APCO"), East Shahid Atefi Street 35, Africa Boulevard, PO Box
19395-4833, Tehran, Iran; No. 303, Mahtab Building, Pardis Cross Road, Golden City, Qeshm, Iran; No. 44, East Atefi St., Africa Blvd., Tehran, Iran;
Website http://nitcshipping.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
AZERBAIJAN CONSTRUCTION, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
BAGHMISHEH RESIDENTIAL DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
BANCO INTERNACIONAL DE DESARROLLO, C.A. (a.k.a. "BID"), Urb. El Rosal, Av. Francisco de Miranda Edificio Dozsa - Piso 8, C.P. 1060, Caracas,
Venezuela; SWIFT/BIC IDUNVECA; Website www.bid.com.ve; Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR]
(Linked To: EXPORT DEVELOPMENT BANK OF IRAN).
BANDAR IMAM PETROCHEMICAL COMPANY, North Kargar Street, Tehran, Iran; Mahshahr, Bandar Imam, Khuzestan Province, Iran; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN].
BANK KARGOSHAEE, 587 Mohammadiye Square, Mowlavi Street, Tehran, Iran; Mohamadiyeh Square, Tehran 11986, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions; All Offices Worldwide [SDGT] [IFSR] (Linked To: BANK MELLI IRAN).
BANK KESHAVARZI IRAN (a.k.a. AGRICULTURAL BANK OF IRAN; a.k.a. BANK KESHAVARZI), PO Box 14155-6395, 129 Patrice Lumumba St, Jalalal-
Ahmad Expressway, Tehran 14454, Iran; all offices worldwide [IRAN].
BANK MARKAZI JOMHOURI ISLAMI IRAN (a.k.a. BANK MARKAZI IRAN; a.k.a. CENTRAL BANK OF IRAN; a.k.a. CENTRAL BANK OF THE ISLAMIC
REPUBLIC OF IRAN), PO Box 15875/7177, 144 Mirdamad Blvd, Tehran, Iran; 213 Ferdowsi Avenue, Tehran 11365, Iran; Additional Sanctions
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 4/83
Information - Subject to Secondary Sanctions [IRAN].
BANK MASKAN (a.k.a. HOUSING BANK (OF IRAN)), PO Box 11365/5699, No 247 3rd Floor Fedowsi Ave, Cross Sarhang Sakhaei St, Tehran, Iran; all
offices worldwide [IRAN].
BANK MELLI IRAN (a.k.a. BANK MELLI; a.k.a. MELLI BANK; a.k.a. NATIONAL BANK OF IRAN; a.k.a. "BMI"), Ferdowsi Avenue - PO Box 11365-171,
Tehran, Iran; 43 Avenue Montaigne, Paris 75008, France; Room 704-6, Wheelock Hse, 20 Pedder St, Hong Kong; Bank Melli Iran Bldg, 111 St 24, 929
Arasat, Baghdad, Iraq; PO Box 2643, Ruwi, 112, Muscat, Oman; PO Box 2656, Liva Street, Abu Dhabi, United Arab Emirates; PO Box 248, Hamad Bin
Abdulla St, Fujairah, United Arab Emirates; PO Box 1888, Clock Tower, Industrial Rd, Al Ain Club Bldg, Al Ain, Abu Dhabi, United Arab Emirates; PO
Box 1894, Baniyas St, Deira, Dubai, United Arab Emirates; PO Box 5270, Oman Street Al Nakheel, Ras Al-Khaimah, United Arab Emirates; PO Box
459, Al Borj St, Sharjah, United Arab Emirates; PO Box 3093, Ahmed Seddiqui Bldg, Khalid Bin El-Walid St, Bur-Dubai, Dubai, United Arab Emirates;
PO Box 1894, Al Wasl Rd, Jumeirah, Dubai, United Arab Emirates; Postfach 112 129, Holzbruecke 2, 20421, Hamburg, Germany; 23 Nobel Avenue,
Baku, Azerbaijan; Bank Melli Iran Building, Ferdowsi Avenue, Tehran 11365-144, Iran; No. 136 Mirdamad Boulevard, Opposite Al-ghadir Mosque,
Tehran, Iran; Al Ashar Estiqlal Street - Hal Al Zohor, Basra, Iraq; 98a Kensington High Street, London W8 4SG, United Kingdom; 767 5th Ave, 44th Fl,
New York, NY 10153, United States; PO Box 1420, New York, NY 10153, United States; Website www.bmi.ir; Additional Sanctions Information - Subject
to Secondary Sanctions; All Offices Worldwide [IRAN] [SDGT] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS
FORCE).
BANK OF INDUSTRY AND MINE (a.k.a. BANK OF INDUSTRY & MINE; a.k.a. BANK SANAD VA MADAN; a.k.a. "BIM"), 1655 Vali-E-Asr After Chamran
Crossroad, Tehran, Iran; PO Box 15875-4456, Firouzeh Tower, No 2917 Vali-Asr Ave (after Chamran Crossroads), Tehran 1965643511, Iran;
SWIFT/BIC BOIMIRTH; Website www.bim.ir; Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number 38705 (Iran); All
Offices Worldwide [IRAN] [NPWMD] [IFSR] (Linked To: BANK SEPAH).
BANK REFAH KARGARAN (a.k.a. BANK REFAH; a.k.a. WORKERS' WELFARE BANK (OF IRAN)), No. 40 North Shiraz Street, Mollasadra Ave, Vanak
Sq, Tehran 19917, Iran; all offices worldwide [IRAN].
BANK SEPAH INTERNATIONAL PLC, 5/7 Eastcheap, EC3M 1JT, London, United Kingdom; SWIFT/BIC SEPBGB2L; Website www.banksepah.co.uk;
alt. Website www.banksepah.com; Additional Sanctions Information - Subject to Secondary Sanctions [NPWMD] [IFSR] (Linked To: BANK SEPAH).
BANK SEPAH, Negin Sepah Building, Head Office of Bank Sepah, Nowrouz Street, Africa Hwy, Argentina Square, Tehran, Iran; 6th Floor, Negin Sepah
Building, Nowrouz St., Africa Hwy., Argentina Sq., Tehran 1519662840, Iran; Imam Khomeini Square - PO Box 11364, Tehran, Iran; Hafenstrasse 54,
D-60327, Frankfurt am Main, Germany; PO Box 110261, Franfurt am Main, Hessen 60037, Germany; 20 Rue Auguste Vacquerie, Paris 75016, France;
Via Barberini 50, Rome 00187, Italy; SWIFT/BIC SEPBIRTH; Website www.banksepah.ir; alt. Website www.banksepah.de; Additional Sanctions
Information - Subject to Secondary Sanctions; Registration Number 4293; All Offices Worldwide [IRAN] [NPWMD] [IFSR] (Linked To: MINISTRY OF
DEFENSE FOR ARMED FORCES LOGISTICS).
BANK TEJARAT (a.k.a. TEJARAT BANK), 152 Taleghani Avenue, Tehran, Iran; No. 247, Taleghani Avenue, Tehran, Iran; PO Box 11365-3139, 130
Taleghani Avenue, Tehran, Iran; PO Box 1598617818, Tehran, Iran; PO Box 71345, Karim Khan Zand Blv, Nouri Ave, Opposite Eram Hotel, Shiraz,
Iran; 124-126 Rue de Provence, (Angle 76 bd Haussmann), Paris 75008, France; PO Box 734001, Rudaki Ave 88, Dushanbe 734001, Tajikistan; Office
C208, Beijing Lufthansa Center No 50, Liangmaqiao Rd, Chaoyang District, Beijing 100016, China; PO Box 119871, 4th Floor, c/o Persia International
Bank PLC, The Gate Bldg, Dubai, United Arab Emirates; Esfahan Region Management Bldg, Sheikh Bahayee Ave & Abuzar St Junction, Esfahan, Iran;
SWIFT/BIC BTEJIRTH; Website www.tejaratbank.ir; Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number 38027;
alt. Registration Number 8828215; All Offices Worldwide [IRAN] [SDGT] [NPWMD] [IFSR] (Linked To: MAHAN AIR; Linked To: BANK SEPAH).
BANK TORGOVOY KAPITAL ZAO (a.k.a. BANK TORGOVOY KAPITAL; a.k.a. BANK TORGOVY KAPITAL; a.k.a. TRADE CAPITAL BANK; a.k.a. "TC
BANK"; a.k.a. "TK BANK"), 65A Timiriazeva, Minsk 220035, Belarus; SWIFT/BIC BBTKBY2X; Website www.tcbank.by; Additional Sanctions
Information - Subject to Secondary Sanctions; Registration Number 807000163 (Belarus) [IRAN] [SDGT] [NPWMD] [IFSR] (Linked To: BANK
TEJARAT).
BANK-E SHAHR, Sepahod Gharani, Corner of Khosro St., No. 147, Tehran, Iran [IRAN].
BEHSAZ KASHANE TEHRAN CONSTRUCTION CO. (a.k.a. BEHSAZ KASHANEH CO.), No. 40, East Street Journal, North Shiraz Street, Sadra
Avenue, Tehran, Iran; Website http://www.behsazco.ir; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
BEHSAZAN PARS EQUIPMENT DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
BEHSHAHR INDUSTRIAL DEVELOPMENT CORP., Number 8, 24 Alley, Past Motahari Street, Ghaem Magham Farahani Street, Tehran, Iran; Website
www.bidc.ir; Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number 14393 (Iran) [SDGT] [IFSR] (Linked To: TOSE-E
MELLI GROUP INVESTMENT COMPANY).
BELIZE SHIP AND LOGISTIC LIMITED (a.k.a. BELIZE SHIP & LOGISTIC LTD; a.k.a. BELIZE SHIP AND LOGISTIC LTD), East Shahid Atefi Street 35,
Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL
IRANIAN TANKER COMPANY).
BELIZE SHIPPING LINE SERVICE LIMITED (a.k.a. BELIZE SHIPPING LINE SERV LTD), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-
4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BIIS MARITIME LIMITED, 147/1, St. Lucia Street, Valletta VLT1185, Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Trade
License No. C31530 (Malta) [IRAN].
BIMEH IRAN INSURANCE COMPANY (U.K.) LIMITED (a.k.a. BIUK), 4/5 Fenchurch Buildings, London EC3M 5HN, United Kingdom; Additional
Sanctions Information - Subject to Secondary Sanctions; UK Company Number 01223433 (United Kingdom); all offices worldwide [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 5/83
BLUE TANKER SHIPPING SA, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044,
Fujairah, United Arab Emirates; Majuro MH, Marshall Islands; Liberia; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
BMIIC INTERNATIONAL GENERAL TRADING L.L.C., 705 International Business Tower, PO Box 181878, Dubai, United Arab Emirates; Additional
Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: TOSE-E MELLI GROUP INVESTMENT COMPANY).
BOU ALI SINA PETROCHEMICAL COMPANY (a.k.a. BUALI SINA PETROCHEMICAL COMPANY), No. 17, 1st Floor, Daman Afshar St., Vanak Sq.,
Vali-e-Asr Ave, Tehran 19697, Iran; Petrochemical Special Economic Zone (PETZONE), Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN].
BREYELLER STAHL TECHNOLOGY GMBH & CO. KG (a.k.a. BREYELLER STAHL TECHNOLOGY GMBH AND CO. KG; f.k.a. ROETZEL-STAHL
GMBH & CO. KG; f.k.a. ROETZEL-STAHL GMBH AND CO. KG), Josefstrasse 82, Nettetal 41334, Germany; Additional Sanctions Information - Subject
to Secondary Sanctions; Registration ID HRA 4528 (Germany); all offices worldwide [IRAN].
BUALI INVESTMENT COMPANY, No. 13, 11th (Shahab) Street, Gandy Blvd, Tehran, Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
BUSHEHR SHIPPING COMPANY LIMITED, 143/1 Tower Road, Sliema, Malta; Additional Sanctions Information - Subject to Secondary Sanctions;
Trade License No. C 37422 (Malta) [IRAN].
CASPIAN MARITIME LIMITED, Fortuna Court, Block B, 284 Archbishop Makarios II Avenue, Limassol 3105, Cyprus; Additional Sanctions Information -
Subject to Secondary Sanctions; Telephone (357)(25800000); Fax (357)(25588055) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
CEMENT INDUSTRY INVESTMENT AND DEVELOPMENT COMPANY, Number 20, W. Nahid Street, Africa Blvd, Tehran, Iran; Website www.cidco.ir;
Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number 218006 (Iran) [SDGT] [IFSR] (Linked To: TOSE-E MELLI
GROUP INVESTMENT COMPANY).
COMMERCIAL PARS OIL CO., 9th Floor, No. 346, Mirdamad Avenue, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions
[IRAN].
CREDIT INSTITUTION FOR DEVELOPMENT, 53 Saanee, Jahan-e Koodak, Crossroads Africa St., Tehran, Iran; Additional Sanctions Information -
Subject to Secondary Sanctions [IRAN].
CYLINDER SYSTEM L.T.D. (a.k.a. CILINDER SISTEM D.O.O.; a.k.a. CILINDER SISTEM D.O.O. ZA PROIZVODNJU I USLUGE), Dr. Mile Budaka 1,
Slavonski Brod 35000, Croatia; 1 Mile Budaka, Slavonski Brod 35000, Croatia; Website http://www.csc-sb.hr; Additional Sanctions Information - Subject
to Secondary Sanctions; Registration ID 050038884 (Croatia); Tax ID No. 27694384517 (Croatia) [IRAN].
DAMAVAND ELECTRICITY AND POWER ENGINEERING, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
DAMAVAND POWER GENERATION COMPANY, No. 6, Boostan Alley, Attar Street, N. Kurdistan Highway, Tehran, Iran; Website
www.damavandpg.co.ir; Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
DANA INTEGRATED SYSTEM FOR ELECTRONIC INTERACTIONS CO. (a.k.a. SAMANEHAYE YEKPARCHEH TAMOLAT ELECTRONIC DANA),
Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
DANESH SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information
- Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DARYA CAPITAL ADMINISTRATION GMBH, Schottweg 5, Hamburg 22087, Germany; Additional Sanctions Information - Subject to Secondary
Sanctions; Trade License No. HRB 96253 [IRAN].
DARYANAVARD KISH (a.k.a. DARYANAVARD KISH SHIPPING COMPANY; a.k.a. DARYANAVARD KISH SHIPPING COMPANY LTD.), Unit7, No. 3,
Noor Alley, Nelsonmandella Blvd., Tehran, Iran; Kish Islands, Iran; Website http://nitcshipping.com; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DAVAR SHIPPING CO LTD, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information - Subject to
Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22678777) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DAY BANK (a.k.a. DEY BANK), 45 Vali Asr Ave, Parvin St, Tehran 1966835611, Iran; SWIFT/BIC DAYBIRTH; Additional Sanctions Information - Subject
to Secondary Sanctions; All Offices Worldwide [IRAN] [SDGT] [IFSR] (Linked To: MARTYRS FOUNDATION).
DAY BANK BROKERAGE COMPANY, No. 58, 2nd, 3rd, and 4th floors, 14th street, Khaled Istanbuli Street, Tehran, Iran; Website
www.daybankbroker.com; Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
DAY E-COMMERCE, No. 66, Mansour Alley, Next to Tehran Grand Hotel, Motahari Street, Tehran, Iran; Website www.dec.ir; Additional Sanctions
Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
DAY EXCHANGE COMPANY, No. 239, First Floor of Day Insurance Building, Mirdamad Blvd, Tehran, Iran; Website www.dayexchange.ir; Additional
Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
DAY INVESTMENT (a.k.a. SARMAYE GOZARI DAY), Iran [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 6/83
DAY IRANIAN FINANCIAL AND ACCOUNTING SERVICES COMPANY, No. 4, 4th Floor, Farid Afshar Street, Shahid Dastgerdi Street, Tehran, Iran;
Website http://fsday.ir; Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
DAY LEASING COMPANY, No. 5, Shahid Dademan Street, N. Gol Afshan, W. Ivanak, Shahrak Qarb, Tehran, Iran; Website https://leasingday.ir;
Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
DENA TANKERS FZE, Free Zone, P.O. Box 5232 , Fujairah, United Arab Emirates; Additional Sanctions Information - Subject to Secondary Sanctions
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DIAMOND TRANSPORTATION LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DIMOND TRANSPORTATION LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
EDBI EXCHANGE BROKERAGE (a.k.a. EDBI EXCHANGE COMPANY), Tehran, Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [SDGT] [IFSR] (Linked To: EXPORT DEVELOPMENT BANK OF IRAN).
EDBI STOCK BROKERAGE, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: EXPORT
DEVELOPMENT BANK OF IRAN).
EGHTESAD NOVIN BANK (a.k.a. BANK-E EGHTESAD NOVIN; a.k.a. EN BANK PJSC), Vali Asr Street, Above Vanak Circle, across Niayesh,
Esfandiari Blvd., No. 24, Tehran, Iran; SWIFT/BIC BEGNIRTH [IRAN].
EIGHTH OCEAN GMBH & CO. KG (a.k.a. EIGHTH OCEAN GMBH AND CO. KG), Schottweg 5, Hamburg 22087, Germany; Additional Sanctions
Information - Subject to Secondary Sanctions; Trade License No. HRA 102533 [IRAN].
ELEVENTH OCEAN ADMINISTRATION GMBH, Schottweg 5, Hamburg 22087, Germany; Additional Sanctions Information - Subject to Secondary
Sanctions; Trade License No. HRB94632 [IRAN].
ELEVENTH OCEAN GMBH & CO. KG (a.k.a. ELEVENTH OCEAN GMBH AND CO. KG), Schottweg 5, Hamburg 22087, Germany; Additional Sanctions
Information - Subject to Secondary Sanctions; Trade License No. HRA 102544 [IRAN].
EMPIRE MARITIME SERVICES LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ESAIL SHIPPING LIMITED (a.k.a. E-SAIL SHIPPING COMPANY LTD; f.k.a. SANTEX LINES), Building 1088, Suite 1501, Pudong South Road
(Shanghai Zhong Rong Plaza), Shanghai 200122, China; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License No.
1429927 (Hong Kong) [IRAN].
EUROPAISCH-IRANISCHE HANDELSBANK AG (a.k.a. EUROPAEISCH-IRANISCHE HANDELSBANK AKTIENGESELLSCHAFT; a.k.a.
EUROPAISCH-IRANISCHE HANDELSBANK AKTIENGESELLSCHAFT), Depenau 2, Hamburg 20095, Germany; Postfach 101304, Hamburg 20008,
Germany; PO Box 97415-1836, Sanaee Avenue, Kish, Iran; 28 Tandis St, Nelson Mandela Blvd. (Ex North Africa Blvd.), Tehran 19156-33383, Iran;
SWIFT/BIC EIHBDEHH; alt. SWIFT/BIC EIHBIRTH; Website www.eihbank.de; Additional Sanctions Information - Subject to Secondary Sanctions;
Registration Number HRB 14604 (Germany); All Offices Worldwide [IRAN] [NPWMD] [IFSR] (Linked To: BANK OF INDUSTRY AND MINE).
EUROPE TRANSPORTATION LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
EXECUTION OF IMAM KHOMEINI'S ORDER (a.k.a. EIKO; a.k.a. SETAD; a.k.a. SETAD EJRAEI EMAM; a.k.a. SETAD-E EJRAEI-E FARMAN-E
HAZRAT-E EMAM; a.k.a. SETAD-E FARMAN-EJRAEI-YE EMAM), Khaled Stamboli St., Tehran, Iran; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN].
EXPORT DEVELOPMENT BANK OF IRAN (a.k.a. BANK TOSEE SADERAT IRAN; a.k.a. BANK TOSEH SADERAT IRAN; a.k.a. BANK TOSEYEH
SADERAT IRAN; a.k.a. BANK TOWSEEH SADERAT IRAN; a.k.a. IRANIAN EXPORT DEVELOPMENT BANK; a.k.a. "EDBI"), No. 26, Tosee Tower
(Export Development Building), Corner of 15th Street, Ahmad Qasir Avenue, Argentina Square, Tehran 1513815111, Iran; Website www.edbi.ir;
Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number 86936 (Iran) [IRAN] [SDGT] [IFSR] (Linked To: MB BANK).
FANAVARAN ETEMAAD RAAHBAR CO., Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
FARADARYAY-E NIK-E GHESHM INVESTMENT (a.k.a. NIK QESHM FARA DARYA INVESTMENT COMPANY), Opposite Kimia Hotel 2, Sam & Zal
Street, Qeshm, Hormozgan 7951189799, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
FARS SARPANAH, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
FIFTEENTH OCEAN GMBH & CO. KG (a.k.a. FIFTEENTH OCEAN GMBH AND CO. KG), Schottweg 5, Hamburg 22087, Germany; Additional
Sanctions Information - Subject to Secondary Sanctions; Trade License No. HRA 104175 [IRAN].
FIRST EAST EXPORT BANK PLC (a.k.a. FEE BANK MALAYSIA), Unit Level 10(B1), Main Office Tower, Financial Park, Jalan Merdeka, 87000 Labuan
F.T., Wilayah Persekutuan, Malaysia; SWIFT/BIC FEEBMYKA; Additional Sanctions Information - Subject to Secondary Sanctions; All Offices
Worldwide [SDGT] [IFSR] (Linked To: BANK MELLAT).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 7/83
FIRST ISLAMIC INVESTMENT BANK LIMITED (a.k.a. "FIIB"), 19A-3A-3A, Level 31, Business Suite, UOA Centre, No. 19 Jalan, Pinang, Kuala Lumpur
50450, Malaysia; Financial Park Labuan Complex Unit 13 (C), Main Office Tower Jalan Merdeka, Labuan 87000, Malaysia; Website www.fiib.com.my;
Additional Sanctions Information - Subject to Secondary Sanctions [NPWMD] [IFSR].
FIRST OCEAN ADMINISTRATION GMBH, Schottweg 5, Hamburg 22087, Germany; Additional Sanctions Information - Subject to Secondary Sanctions;
Trade License No. HRB94311 [IRAN].
FIRST OCEAN GMBH & CO KG (a.k.a. FIRST OCEAN GMBH AND CO KG), Schottweg 5, Hamburg 22087, Germany; Additional Sanctions Information
- Subject to Secondary Sanctions; Trade License No. HRA 102601 [IRAN].
FOURTEENTH OCEAN GMBH & CO. KG (a.k.a. FOURTEENTH OCEAN GMBH AND CO. KG), Schottweg 5, Hamburg 22087, Germany; Additional
Sanctions Information - Subject to Secondary Sanctions; Trade License No. HRA 104174 [IRAN].
FOURTH OCEAN GMBH & CO KG (a.k.a. FOURTH OCEAN GMBH AND CO KG), Schottweg 5, Hamburg 22087, Germany; Additional Sanctions
Information - Subject to Secondary Sanctions; Trade License No. HRA102600 [IRAN].
FUTURE AGE SHIPPING LIMITED (a.k.a. FUTURE AGE SHIPPING LTD.), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran,
Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
FUTURE BANK B.S.C. (a.k.a. FUTURE BANK; a.k.a. FUTUREBANK), Building 2577, Road 2833, Block Al-Seef 428, PO Box 785, Manama, Bahrain;
Website www.futurebank.com.bh; Additional Sanctions Information - Subject to Secondary Sanctions; All Offices Worldwide [IRAN] [SDGT] [IFSR]
(Linked To: BANK MELLI IRAN).
GARBIN NAVIGATION LTD, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044, Fujairah,
United Arab Emirates; 80 Broad Street, Monrovia, Liberia; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
GHADIR ABU MUSA HAMOON, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
GHADIR CASPIAN GILAN ENERGY, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
GHADIR CASPIAN STEEL TRADING, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
GHADIR ELECTRICITY AND ENERGY INVESTMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
GHADIR ETEZAD INVESTMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
GHADIR INDUSTRIAL TRADING, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
GHADIR INTERNATIONAL TRADING AND DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked
To: GHADIR INVESTMENT COMPANY).
GHADIR INVESTMENT AND INDUSTRY DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
GHADIR INVESTMENT COMPANY, 341 West Mirdamad Boulevard, Tehran, Iran; P.O. Box 19696, Tehran, Iran; Website http://www.ghadir-invest.com;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
GHADIR KANI ARIYA, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
GHADIR KHUZESTAN CONSTRUCTION INDUSTRY DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN]
(Linked To: GHADIR INVESTMENT COMPANY).
GHADIR LAMORD ENERGY, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
GHADIR MANAGEMENT AND COMMERCIAL SERVICES, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
GHADIR MAZANDARAN ELECTRICITY AND ENERGY GENERATION, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN]
(Linked To: GHADIR INVESTMENT COMPANY).
GHADIR MEHRIZ SOLAR ENERGY, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
GHADIR OXIN ELECTRICITY GENERATION DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked
To: GHADIR INVESTMENT COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 8/83
GHADIR PAYMAN COUNSELING ENGINEERS, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
GHADIR PETRO ARMAN KISH, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
GHADIR PISHRO ELECTRICITY GENERATION, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
GHADIR QOM SOLAR ENERGY GENERATION DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN]
(Linked To: GHADIR INVESTMENT COMPANY).
GHADIR REAL-TIME SYSTEMS DEVELOPMENT (a.k.a. GHADIR TOSE-E SAAMANEHAYE BEHENGAAM; a.k.a. "ISEEMA"), Iran; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
GHADIR SOLAR ELECTRICITY AND ENERGY, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
GHADIR TEHRAN ELECTRICITY AND ENERGY GENERATION DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
GHAED BASSIR PETROCHEMICAL PRODUCTS COMPANY (a.k.a. GHAED BASSIR), No. 15, Palizvani (7th) Street, Gandhi (South) Avenue, Tehran
1517655711, Iran; Km 10 of Khomayen Road, Golpayegan, Iran; Website http://www.gbpc.net; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN].
GHARZOLHASANEH RESALAT BANK, Beside the No. 1 Baghestan Alley, Saadat Abad Ave., Kaj Sq., Tehran, Iran; All offices worldwide [IRAN].
GHAVAMIN BANK (a.k.a. BANK QAVAMIN; f.k.a. GHAVAMIN FINANCIAL & CREDIT INS.; a.k.a. QAVAMIN BANK; a.k.a. QAVVAMIN BANK), Ghavamin
Tower, Argentina Sq., Tehran, Iran; Website www.ghbi.ir; Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number
397957 (Iran) [IRAN] [IRAN-HR] (Linked To: LAW ENFORCEMENT FORCES OF THE ISLAMIC REPUBLIC OF IRAN).
GHESHM SHIPPING LINES MARINE AND ENGINEERING SERVICES CO (a.k.a. IMSENGCO; a.k.a. IRISL MARINE SERVICES; a.k.a. IRISL
MARINE SERVICES AND ENGINEERING COMPANY), Iran shahr Street 221, Karimkhan Zand Avenue, Tehran, Iran; Website www.imsengco.com;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
GILAN ELECTRICITY GENERATION MANAGEMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
GILAN ELECTRICITY TRANSMISSION DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
GLOBAL AGE LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
GLOBAL UNITED SHIPPING LIMITED (a.k.a. GLOBAL UNITED SHIPPING LTD-BZE), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-
4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
GOLDEN ENTERPRISE SHIPPING LIMITED (a.k.a. GOLDEN ENTERPRISE SHIPPING LTD), East Shahid Atefi Street 35, Africa Boulevard, PO Box
19395-4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
GOLDEN RESOURCES TRADING COMPANY L.L.C. (a.k.a. "GRTC"), 9th Floor, Office No. 905, Khalid Al Attar Tower 1, Sheikh Zayed Road, After
Crown Plaza Hotel, Al Wasl Area, Dubai, United Arab Emirates; Postal Box 34489, Dubai, United Arab Emirates; Postal Box 14358, Dubai, United Arab
Emirates; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
GRACE BAY SHIPPING INC, Care of Sambouk Shipping FCZ, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044, Fujairah, United
Arab Emirates; Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro MH96960, Marshall Islands; Additional Sanctions Information - Subject
to Secondary Sanctions [IRAN].
HADI SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HAFEZ DARYA ARYA SHIPPING COMPANY (a.k.a. HAFEZ DARYA ARYA SHIPPING LINE; a.k.a. HAFEZ-E DARYAY-E ARIA SHIPPING LINES; f.k.a.
HAFIZ DARYA SHIPPING COMPANY; f.k.a. HAFIZ-E-DARYA SHIPPING LINES; a.k.a. HDAS CO.; f.k.a. HDAS LINES; a.k.a. HDASCO; a.k.a.
HDASCO SHIPPING COMPANY; f.k.a. HDS LINES; f.k.a. HDSL; f.k.a. HDSLINES CO.), Asseman Tower, Pasdaran Street, Tehran, Iran; No 60,
Pasdaran Avenue, 7th Neyestan Street, Ehteshamiyeh Square, Tehran, Iran; Website www.hdasco.com; Additional Sanctions Information - Subject to
Secondary Sanctions; Registration Number 341417 (Iran) [IRAN].
HAMOON SEPAHAN COMMERCIAL TRADING, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
HAMOON SEPAHAN INVESTMENT, Iran [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 9/83
HAMOON SEPAHAN MANAGEMENT SERVICES, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
HARAZ SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HATEF SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HEKMAT IRANIAN BANK (a.k.a. BANK-E HEKMAT IRANIAN), Argentine Circle, beginning of Africa St., Corner of 37th St., (Dara Cul-de-sac), No.26,
Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
HERCULES INTERNATIONAL SHIP, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044,
Fujairah, United Arab Emirates; 80 Broad Street, Monrovia, Liberia; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
HERMIS SHIPPING SA, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044, Fujairah,
United Arab Emirates; Panama City, Panama; Monrovia, Liberia; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
HIRMAND SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
HODA SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HOMA SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HONAR SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HONG KONG INTERTRADE COMPANY, Hong Kong; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
HOOPAD DARYA SHIPPING AGENCY SERVICES (a.k.a. HOOPAD DARYA SHIPPING AGENCY COMPANY; f.k.a. SOUTH WAY SHIPPING
AGENCY), No. 101, Shabnam Alley, Ghaem Magham Street, Tehran, Iran; Hoopad Darya Shipping Agency Building, B.I.K. Port Complex, Bandar
Imam Khomeini, Iran; Hoopad Darya Shipping Agency Building, Imam Khomeini Blvd, Bandar Abbas, Iran; Flat No. 2, 2nd Floor, SSL Building, Coastal
Blvd, Between City Hall and Post Office, Khorramshahr, Iran; Opposite to City Post Office, No. 2 Telecommunications Center, Bandar Assaluyeh, Iran;
PO Box 1589673134, Tehran, Iran; Website www.hdsac.net; Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number
349706 (Iran) [IRAN].
HORMOGAN ELECTRICITY AND POWER GENERATION, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
HORMOZ OIL REFINING COMPANY, Next to the Current Bandar Abbas Refinery, Bandar Abbas City, Iran; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN].
HTTS HANSEATIC TRADE TRUST & SHIPPING GMBH (a.k.a. HTTS HANSEATIC TRADE TRUST AND SHIPPING GMBH), Schottweg 5-7, Hamburg
22087, Germany; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License No. HRB 109492 [IRAN].
IFIC HOLDING AG (a.k.a. IHAG), Koenigsallee 60 D, Dusseldorf 40212, Germany; Additional Sanctions Information - Subject to Secondary Sanctions;
Registration ID HRB 48032 (Germany); all offices worldwide [IRAN].
IHAG TRADING GMBH, Koenigsallee 60 D, Dusseldorf 40212, Germany; Additional Sanctions Information - Subject to Secondary Sanctions;
Registration ID HRB 37918 (Germany); all offices worldwide [IRAN].
IMPIRE SHIPPING COMPANY (a.k.a. IMPIRE SHIPPING; a.k.a. IMPIRE SHIPPING LIMITED), Greece; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN].
INDUSTRIAL DEVELOPMENT AND RENOVATION ORGANIZATION OF IRAN (a.k.a. IDRO; a.k.a. IRAN DEVELOPMENT & RENOVATION
ORGANIZATION COMPANY; a.k.a. IRAN DEVELOPMENT AND RENOVATION ORGANIZATION COMPANY; a.k.a. SAWZEMANE GOSTARESH VA
NOWSAZI SANAYE IRAN), Vali Asr Building, Jam e Jam Street, Vali Asr Avenue, Tehran 15815-3377, Iran; Additional Sanctions Information - Subject
to Secondary Sanctions; all offices worldwide [IRAN].
INTERNATIONAL EXPERTISE GROUP LIMITED (a.k.a. INTERNATIONAL EXPERTISE GROUP; a.k.a. INTERNATIONAL EXPERTISE GROUP LTD.),
East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
INTERNATIONAL TANKER LIMITED (a.k.a. "INTERNATIONAL TANKER LTD"), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833,
Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
INTERSEAS SHIPYARD LTD, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information -
Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 10/83
INTRA CHEM TRADING GMBH (a.k.a. INTRA-CHEM TRADING CO. (GMBH)), Schottweg 3, Hamburg 22087, Germany; Additional Sanctions
Information - Subject to Secondary Sanctions; Registration ID HRB48416 (Germany); all offices worldwide [IRAN].
IRAN & SHARGH COMPANY (a.k.a. IRAN AND EAST COMPANY; a.k.a. IRAN AND SHARGH COMPANY; a.k.a. IRANOSHARGH COMPANY; a.k.a.
SHERKAT-E IRAN VA SHARGH), 827, North of Seyedkhandan Bridge, Shariati Street, P.O. Box 13185-1445, Tehran 16616, Iran; No. 41, Next to 23rd
Alley, South Gandi St., Vanak Square, Tehran 15179, Iran; Website http://www.iranoshargh.com; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN].
IRAN & SHARGH LEASING COMPANY (a.k.a. IRAN AND EAST LEASING COMPANY; a.k.a. IRAN AND SHARGH LEASING COMPANY; a.k.a.
SHERKAT-E LIZING-E IRAN VA SHARGH), 1st Floor, No. 33, Shahid Atefi Alley, Opposite Mellat Park, Vali-e-Asr Street, Tehran 1967933759, Iran;
Website http://www.isleasingco.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
IRAN AIR (a.k.a. HAVAPEYMAYI MELLI IRAN; a.k.a. IRAN AIR PJSC; a.k.a. IRANAIR; a.k.a. IRANAIR CARGO; a.k.a. THE AIRLINE OF THE ISLAMIC
REPUBLIC OF IRAN; a.k.a. "HOMA"), Iran Air Building, Mehrabad Airport, Tehran, Iran; Postal Box 13185-775, Tehran, Iran; Central Airlines
Department of the Islamic Republic of Iran, Tehran Karaj Special Road, Beginning of Mehrabad International Airport, Tehran, Iran; Website
www.iranair.com; alt. Website www.iranair.co.ir; Additional Sanctions Information - Subject to Secondary Sanctions; National ID No. 10100354259
(Iran); Registration Number 8132 [IRAN].
IRAN FOREIGN INVESTMENT COMPANY (a.k.a. IFIC), No. 4, Saba Blvd., Africa Blvd., Tehran 19177, Iran; P.O. Box 19395-6947, Tehran, Iran;
Additional Sanctions Information - Subject to Secondary Sanctions; all offices worldwide [IRAN].
IRAN INSURANCE COMPANY (a.k.a. BIMEH IRAN), 107 Dr Fatemi Avenue, Tehran 14155/6363, Iran; Abdolaziz-Al-Masaeed Building, Sheikh
Maktoom St., Deira, P.O. Box 2004, Dubai, United Arab Emirates; P.O. Box 1867, Al Ain, Abu Dhabi, United Arab Emirates; P.O. Box 3281, Abu Dhabi,
United Arab Emirates; P.O. Box 1666, Sharjah, United Arab Emirates; P.O. Box 849, Ras-Al-Khaimah, United Arab Emirates; P.O. Box 417, Muscat
113, Oman; P.O. Box 676, Salalah 211, Oman; P.O. Box 995, Manama, Bahrain; Al-Lami Center, Ali-Bin-Abi Taleb St. Sharafia, P.O. Box 11210, Jeddah
21453, Saudi Arabia; Al Alia Center, Salaheddine Rd., Al Malaz, P.O. Box 21944, Riyadh 11485, Saudi Arabia; Al Rajhi Bldg., 3rd Floor, Suite 23,
Dhahran St., P.O. Box 1305, Dammam 31431, Saudi Arabia; Additional Sanctions Information - Subject to Secondary Sanctions; all offices worldwide
[IRAN].
IRAN MERINE SERVICES, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
IRAN NUCLEAR REGULATORY AUTHORITY (a.k.a. "INRA"), Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN]
(Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
IRAN PETROCHEMICAL COMMERCIAL COMPANY (a.k.a. PETROCHEMICAL COMMERCIAL COMPANY; a.k.a. SHERKATE BASARGANI
PETROCHEMIE (SAHAMI KHASS); a.k.a. SHERKATE BAZARGANI PETRCHEMIE; a.k.a. "IPCC"; a.k.a. "PCC"), No. 1339, Vali Nejad Alley, Vali-e-Asr
St., Vanak Sq., Tehran, Iran; INONU CAD. SUMER Sok., Zitas Bloklari C.2 Bloc D.H, Kozyatagi, Kadikoy, Istanbul, Turkey; Topcu Ibrahim Sokak No: 13
D: 7 Icerenkoy-Kadikoy, Istanbul, Turkey; 99-A, Maker Tower F, 9th Floor, Cuffe Parade, Colabe, Mumbai 400 005, India; No. 1014, Doosan We've
Pavilion, 58, Soosong-Dong, Jongno-Gu, Seoul, Korea, South; Office No. 707, No. 10, Chao Waidajie, Chao Tang District, Beijing 100020, China;
Additional Sanctions Information - Subject to Secondary Sanctions; all offices worldwide [IRAN].
IRAN ZAMIN BANK (a.k.a. BANK-E IRAN ZAMIN), Seyyed Jamal-oldin Asadabadi St., Corner of 68th St., No. 472, Tehran, Iran [IRAN].
IRANIAN MINES AND MINING INDUSTRIES DEVELOPMENT AND RENOVATION ORGANIZATION (a.k.a. IMIDRO; a.k.a. IRAN MINING
INDUSTRIES DEVELOPMENT AND RENOVATION ORGANIZATION; a.k.a. IRANIAN MINES AND MINERAL INDUSTRIES DEVELOPMENT AND
RENOVATION), No. 39, Sepahbod Gharani Avenue, Ferdousi Square, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions;
all offices worldwide [IRAN].
IRANIAN NOVIN INDUSTRY DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
IRANIAN OIL COMPANY (U.K.) LIMITED (a.k.a. IOC UK LTD), Riverside House, Riverside Drive, Aberdeen AB11 7LH, United Kingdom; Additional
Sanctions Information - Subject to Secondary Sanctions; UK Company Number 01019769 (United Kingdom); all offices worldwide [IRAN].
IRANIAN TITANIUM DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
IRANO HIND SHIPPING COMPANY LTD (a.k.a. IRAN AND INDIA SHIPPING COMPANY; a.k.a. IRAN AND INDIA SHIPPING LINES), 18 Sedaghat St,
Opposite Park Millat, Vali-e-Asr Ave, PO Box 15875-4647, Tehran, Iran; Website www.iranohind.com; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN].
IRANO MISR SHIPPING COMPANY (a.k.a. IRAN AND EGYPT SHIPPING COMPANY; a.k.a. IRAN AND EGYPT SHIPPING LINES; a.k.a. IRANO -
MISR SHIPPING CO; a.k.a. IRANO MISR; f.k.a. NEFERTITI SHIPPING AND MARITIME SERVICES), Building 6, Al Horreya Street, 1st Floor, El
Attarin Area, 1016, Alexandria, Egypt; PO Box 1016, Alexandria, Egypt; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
IRAN'S NUCLEAR POWER PLANT CONSTRUCTION MANAGEMENT COMPANY (a.k.a. "MASNA"); Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
IRAN-VENEZUELA BI-NATIONAL BANK (a.k.a. "IVBB"), IVBB Headquarters, 30th Alley, No. 96, Khaled Eslamboli Street, (Vozara), PO Box 15175-598,
Tehran 15119-57111, Iran; Website http://en.ivbb.ir/; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] [SDGT] [IFSR] (Linked
To: EXPORT DEVELOPMENT BANK OF IRAN).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 11/83
IRASCO S.R.L. (a.k.a. IRASCO ITALY), Via Di Francia 3, Genoa 16149, Italy; Additional Sanctions Information - Subject to Secondary Sanctions;
Registration ID GE 348075 (Italy); all offices worldwide [IRAN].
IRISL EUROPE GMBH, Schottweg 5, Hamburg 22087, Germany; Website www.irisl-europe.de; Additional Sanctions Information - Subject to Secondary
Sanctions; Trade License No. HRB 81573 [IRAN].
IRISL MARITIME TRAINING INSTITUTE (a.k.a. IRISL MTI), No. 63, East Tajarloo Ave, Tajarloo Square, Shiyan, Tehran, Iran; Reiesali Delvari Ave,
Bushehr 7514618787, Iran; Farhang Ave, Khazar's Building, Anzali 4314695613, Iran; Website www.irmti.ir; Additional Sanctions Information - Subject
to Secondary Sanctions [IRAN].
IRISL MULTIMODAL TRANSPORT CO., No. 25 Sanaei Street, Karim Khan Zand Street, Shahid Arabi Line, Tehran, Iran; Website www.irislmtc.com;
Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number 230766 [IRAN].
IRITAL SHIPPING LINES COMPANY (a.k.a. IR-ITAL; a.k.a. IRITAL SHIPPING S.R.L.), Via Gerolamo Morone 6, Milano 20121, Italy; Additional
Sanctions Information - Subject to Secondary Sanctions; Trade License No. GE0426505 (Italy) [IRAN].
ISI MARITIME LIMITED, 147/1, St. Lucia Street, Valletta, Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License No.
C 28940 (Malta) [IRAN].
ISIM ATR LIMITED, 147/1, St. Lucia Street, Valletta, Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License No.
C34477 (Malta) [IRAN].
ISIM SININ LIMITED, 147/1, St. Lucia Street, Valletta, Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License No.
C37437 (Malta) [IRAN].
ISIM TAJ MAHAL LIMITED, 147/1, St. Lucia Street, Valletta, Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License
No. C 41660 (Malta) [IRAN].
ISLAMIC REGIONAL COOPERATION BANK (a.k.a. BANK-E TAAWON MANTAGHEEY-E ESLAMI; a.k.a. REGIONAL COOPERATION OF THE
ISLAMIC BANK FOR DEVELOPMENT & INVESTMENT), Building No. 59, District 929, Street No. 17, Arsat Al-Hindia, Al Masbah, Baghdad, Iraq; Tohid
Street, Before Tohid Circle, No. 33, Upper Level of Eghtesad-e Novin Bank, Tehran 1419913464, Iran; SWIFT/BIC RCDFIQBA [IRAN].
ISLAMIC REPUBLIC OF IRAN - CHINA SHIPPING LINES, China; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
ISLAMIC REPUBLIC OF IRAN - MIDDLE EAST SHIPPING LINES COMPANY, Next to CB hotel, Sharaf Building, Office No. 202, Dubai, United Arab
Emirates; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
ISLAMIC REPUBLIC OF IRAN SHIPPING LINES (a.k.a. IRISL), Asseman Tower, Pasdaran Street, Tehran, Iran; P.O. Box 19395-177, Tehran, Iran; P.O.
Box 1957614114, Tehran, Iran; No 523, Al Seman Tower Building, No 8: Narenjestan, Laveltani Street, Sayya Shirazi Square, Pasdaran Street, Tehran
1957617114, Iran; Website www.irisl.net; IFCA Determination - Involved in the Shipping Sector; Additional Sanctions Information - Subject to Secondary
Sanctions; Trade License No. 11670 (Iran); All Offices Worldwide [IRAN] [IFCA].
ISLAMIC REPUBLIC OF IRAN SHIPPING LINES INVESTMENT (a.k.a. ISLAMIC REPUBLIC OF IRAN SHIPPING LINES INVESTMENT COMPANY),
Sky Tower, No. 523, Pasdaran Ave, Farmanieh Ave, Farmanieh, District 1, Tehran 1939513111, Iran; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN].
JABBER IBN HAYAN (a.k.a. JABER IBN HAYAN; a.k.a. JABER IBN HAYAN LABORATORY; a.k.a. JABER IBN HAYAN RESEARCH LABORATORY;
a.k.a. JABR IBN HAYAN MULTIPURPOSE LABORATORY; a.k.a. "JHL"), Tehran, Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
JUPITER SEAWAYS SHIPPING, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044,
Fujairah, United Arab Emirates; 80 Broad Street, Monrovia, Liberia; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
KAFOLATBANK (a.k.a. CJSC KAFOLATBANK), Apartment 4/1, Academics Rajabovs Street, Dushanbe, Tajikistan; SWIFT/BIC KACJTJ22; All offices
worldwide [IRAN].
KALA LIMITED (a.k.a. KALA NAFT LONDON LTD), NIOC House, 4 Victoria Street, Westminster, London SW1H 0NE, United Kingdom; Additional
Sanctions Information - Subject to Secondary Sanctions; UK Company Number 01517853 (United Kingdom); all offices worldwide [IRAN].
KALA PENSION TRUST LIMITED, C/O Kala Limited, N.I.O.C. House, 4 Victoria Street, London SW1H 0NE, United Kingdom; Additional Sanctions
Information - Subject to Secondary Sanctions; UK Company Number 01573317 (United Kingdom); all offices worldwide [IRAN].
KALAN KISH SHIPPING CO (a.k.a. KALAN KISH SHIPPING LINES), Unit 5, 9th Street 2, Ahmad Ghasir Avenue, PO Box 19635-1114, Tehran, Iran;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
KARAFARIN BANK (a.k.a. BANK-E KARAFARIN), Zafar St. No. 315, Between Vali Asr and Jordan, Tehran, Iran; SWIFT/BIC KBIDIRTH [IRAN].
KARAMAAD SYSTEMS MANAGEMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
KASB INTERNATIONAL LLC (a.k.a. FIRST FURAT TRADING LLC), 10th Floor, Citi Bank Building, Oud Metha Road, Oud Metha, Dubai, United Arab
Emirates; Additional Sanctions Information - Subject to Secondary Sanctions; Telephone Number: (971) (4) (3248000) [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 12/83
KERMAN SHIPPING COMPANY LIMITED, 143/1 Tower Road, Sliema, Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Trade
License No. C 37423 (Malta) [IRAN].
KHAVARMIANEH BANK (a.k.a. MIDDLE EAST BANK), No. 22, Second Floor Sabounchi St., Shahid Beheshti Ave., Tehran, Iran; SWIFT/BIC
KHMIIRTH; Additional Sanctions Information - Subject to Secondary Sanctions; All offices worldwide [IRAN].
KHAYBAR COMPANY (a.k.a. KHAYBARCO; a.k.a. KHEYBAR COMPANY; a.k.a. SHERKAT SAHAMI KHASS KHAYBAR), No 97, Ghaem Magham
Farahani Ave, Tehran 1589653313, Iran; PO Box 15815-1966, Tehran, Iran; Website www.khaybarco.ir; Additional Sanctions Information - Subject to
Secondary Sanctions; Chamber of Commerce Number 11047591 (Iran); Registration Number 63383 (Iran) [IRAN].
KHAZAR SEA SHIPPING LINES (a.k.a. DARYA-YE KHAZAR SHIPPING LINES), Shahid Mostafa Khomeini Street, Ghazian Street, PO Box
43145/1711-324, Bandar Azali 4315671145, Iran; Mostafa Khomeini St. Ghazian, PO BOX 4315671145, Anzali Free Zone, Iran; Website
www.khazarshipping.ir; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
KISH ASIA NAVAK, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
KISH INTERNATIONAL BANK (a.k.a. KISH INTERNATIONAL BANK OFFSHORE COMPANY PJS), NBO-9, Andisheh Blvd, Sanayi Street , Kish Island,
Iran; Additional Sanctions Information - Subject to Secondary Sanctions; All offices worldwide [IRAN].
KISH ROOYA-E ZENDEGI, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
KONING MARINE CORP, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044, Fujairah,
United Arab Emirates; 80 Broad Street, Monrovia, Liberia; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
KURDISTAN CEMENT (a.k.a. SIMAN-E KURDISTAN), Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
LONDON IRINVEST SHIP COMPANY (a.k.a. IRINVESTSHIP LIMITED), 10 Greycoat Place, London SW1P 1SB, United Kingdom; Additional Sanctions
Information - Subject to Secondary Sanctions; Trade License No. 04110179 (United Kingdom) [IRAN].
MACHINE SAZI ARAK CO. LTD. (a.k.a. MACHINE SAZI ARAK COMPANY P J S C; a.k.a. MACHINE SAZI ARAK SSA; a.k.a. MASHIN SAZI ARAK;
a.k.a. "MSA"), P.O. Box 148, Arak 351138, Iran; Arak, Km 4 Tehran Road, Arak, Markazi Province, Iran; No. 1, Northern Kargar Street, Tehran 14136,
Iran; Additional Sanctions Information - Subject to Secondary Sanctions; all offices worldwide [IRAN].
MAHAB GHODSS CONSULTING ENGINEERING COMPANY (a.k.a. MAHAB GHODSS CONSULTING ENGINEERING CO.; a.k.a. MAHAB GHODSS
CONSULTING ENGINEERS SSK; a.k.a. MAHAB QODS ENGINEERING CONSULTING CO.), No. 17, Dastgerdy Avenue, Takharestan Alley, 19395-
6875, Tehran 1918781185, Iran; 16 Takharestan Alley, Dastgerdy Avenue, P.O. Box 19395-6875, Tehran 19187 81185, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions; Registration ID 48962 (Iran) issued 1983; all offices worldwide [IRAN].
MAPNA KHUZESTAN ELECTRICITY GENERATION, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
MARANER HOLDINGS LIMITED, Flat 1, 143, Tower Road, Sliema SLM1604, Malta; Additional Sanctions Information - Subject to Secondary Sanctions;
Trade License No. C33482 (Malta) [IRAN].
MARBLE SHIPPING LTD, 143/1 Tower Road, Sliema, Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License No. C
41949 (Malta) [IRAN].
MARINE INFORMATION TECHNOLOGY DEVELOPMENT COMPANY (a.k.a. MARINE INFORMATION TECHNOLOGY DEVELOPMENT
CORPORATION; a.k.a. MARINE TECHNOLOGY AND INFORMATION TECHNOLOGY DEVELOPMENT; a.k.a. MITDCO; a.k.a. "MITD"), 5th Floor, No.
523, Aseman Tower, Pasdaran St., Tehran, Iran; Website www.mitdco.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
MARJAN PETROCHEMICAL COMPANY (a.k.a. MARJAN METHANOL COMPANY), Ground Floor, No. 39, Meftah/Garmsar West Alley, Shiraz (South)
Street, Molla Sadra Avenue, Tehran, Iran; Post Office Box 19935-561, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions
[IRAN].
MB BANK (f.k.a. BANK MELLI IRAN ZAO; a.k.a. JOINT STOCK COMPANY 'MIR BUSINESS BANK'; a.k.a. JSC 'MB BANK'; a.k.a. MB BANK, AO;
a.k.a. MIR BIZNES BANK; a.k.a. MIR BIZNES BANK, AO; a.k.a. MIR BUSINESS BANK; a.k.a. MIR BUSINESS BANK ZAO), 9/1 ul Mashkova,
Moscow 105062, Russia; SWIFT/BIC MRBBRUMM; Website www.mbbru.com; Additional Sanctions Information - Subject to Secondary Sanctions; All
Offices Worldwide [SDGT] [IFSR] (Linked To: BANK MELLI IRAN).
MCS ENGINEERING (a.k.a. EFFICIENT PROVIDER SERVICES GMBH), Karlstrasse 21, Dinslaken, Nordrhein-Westfalen 46535, Germany; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN].
MCS INTERNATIONAL GMBH (a.k.a. MANNESMAN CYLINDER SYSTEMS; a.k.a. MCS TECHNOLOGIES GMBH), Karlstrasse 23-25, Dinslaken,
Nordrhein-Westfalen 46535, Germany; Website http://www.mcs-tch.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
MEHR IRAN CREDIT UNION BANK (a.k.a. BANK-E GHARZOLHASANEH MEHR IRAN; a.k.a. GHARZOLHASANEH MEHR IRAN BANK), Taleghani
St., No.204, Before the intersection of Mofateh, across from the former U.S. embassy, Tehran, Iran; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 13/83
MEHRAN SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
MELLAT BANK CLOSED JOINT-STOCK COMPANY (f.k.a. BANK MELLAT YEREVAN; a.k.a. MELLAT BANK ARMENIA; f.k.a. MELLAT BANK SB
CJSC), PO Box 24, Amiryan Street 6, 0010, Yerevan, Armenia; 5 Tumanyan St, 0001, Yerevan, Armenia; SWIFT/BIC BKMTAM22; Website
www.mellatbank.am; Additional Sanctions Information - Subject to Secondary Sanctions; All Offices Worldwide [SDGT] [IFSR] (Linked To: BANK
MELLAT).
MELLAT INSURANCE COMPANY, No. 48, Haghani Street, Vanak Square, Before Jahan-Kodak Cross, Tehran 1517973913, Iran; No. 40, Shahid
Haghani Express Way, Vanak Square, Tehran, Iran; No. 9, Niloofar Street, Sharabyani Avenue, Taavon Boulevard, Shahr-e-Ziba, Tehran, Iran; 72
Hillview Court, Woking, Surrey GU22 7QW, United Kingdom; No. 697 Saeeidi Alley, Crossroads College, Enghelab St., Tehran, Iran; Website
http://www.mellatinsurance.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
MELLI BANK PLC, 98a Kensington High Street, London W8 4SG, United Kingdom; 4 Moorgate, EC2R 6AL, London, United Kingdom; 18F Kam Sang
Building, 257 Des Voeux Road Central, Hong Kong; 4th Floor, 20 West Nahid Street, Africa Blvd, Tehran, Iran; SWIFT/BIC MELIGB2L; alt. SWIFT/BIC
MELIHKHH; Website www.mellibank.com; Additional Sanctions Information - Subject to Secondary Sanctions; All Offices Worldwide [SDGT] [IFSR]
(Linked To: BANK MELLI IRAN).
MELLI INTERNATIONAL BUILDING & INDUSTRY COMPANY, Number 89, Shahid Khodami Street, After Kurdistan Bridge, Vanak Square, Iran; Website
www.mibic.ir; Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number 85579000 (Iran) [SDGT] [IFSR] (Linked To:
TOSE-E MELLI GROUP INVESTMENT COMPANY).
MERSAD SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
MESBAH ENERGY COMPANY (a.k.a. MESBAH ENERGY), Science & Technology Park, Shahid Ghoddousi Blvd, Arak, Iran; Tehran, Iran; Website
www.isotope.ir; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
METAL & MINERAL TRADE S.A.R.L. (a.k.a. METAL & MINERAL TRADE (MMT); a.k.a. METAL AND MINERAL TRADE (MMT); a.k.a. METAL AND
MINERAL TRADE S.A.R.L.; a.k.a. MMT LUXEMBURG; a.k.a. MMT SARL), 11b, Boulevard Joseph II L-1840, Luxembourg; Additional Sanctions
Information - Subject to Secondary Sanctions; Registration ID B 59411 (Luxembourg); all offices worldwide [IRAN].
MINAB SHIPPING COMPANY LIMITED (f.k.a. MIGHAT SHIPPING COMPANY LIMITED), Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia
1097, Cyprus; Additional Sanctions Information - Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked
To: NATIONAL IRANIAN TANKER COMPANY).
MINES AND METALS ENGINEERING GMBH (a.k.a. "M.M.E."), Georg-Glock-Str. 3, Dusseldorf 40474, Germany; Additional Sanctions Information -
Subject to Secondary Sanctions; Registration ID HRB 34095 (Germany); all offices worldwide [IRAN].
MIRACLE TRANSPORTATION LIMITED (a.k.a. MIRACLE TRANSPORTATION LTD), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-
4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MOALLEM INSURANCE CO., No. 35, Haghani Blvd, Vanak Sq., Tehran 1517973511, Iran; Website www.mic-ir.com; Additional Sanctions Information -
Subject to Secondary Sanctions [IRAN].
MOBIN PETROCHEMICAL COMPANY, South Pars Special Economic Energy Zone, Postal Box: 75391-418, Assaluyeh, Bushehr, Iran; PO Box,
Mashhad, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
MODABER (a.k.a. MODABER INVESTMENT COMPANY; a.k.a. TADBIR INDUSTRIAL HOLDING COMPANY); Additional Sanctions Information -
Subject to Secondary Sanctions [IRAN].
MOMENT INVESTMENT LIMITED (a.k.a. MOMENT INVESTMENT LTD), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran,
Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MOMTAZ ELECTRIC, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
MONSOON SHIPPING LTD, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044, Fujairah,
United Arab Emirates; Valletta, Malta; Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro MH96960, Marshall Islands; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN].
MOSAKHAR DARYA SHIPPING CO (a.k.a. MOSAKHKHAR-E DARYA SHIPPING), Unit 5, 9th Street 2, Ahmad Ghasir Avenue, PO Box 19635-1114,
Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
MOTOJEN AUTO INDUSTRY COMPANY (a.k.a. KHODRO SANAT MOROJEN), Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
MOTOJEN, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
MSP KALA NAFT CO. TEHRAN (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT
TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT;
a.k.a. MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 14/83
PROCUREMENT KALA NAFT COMPANY; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY;
a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a.
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari
Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani
Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran,
Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates; 333
7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao Yang
District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional
Sanctions Information - Subject to Secondary Sanctions; all offices worldwide [IRAN].
N.I.T.C. REPRESENTATIVE OFFICE (a.k.a. NATIONAL IRANIAN TANKER COMPANY), Droogdokweg 71, Rotterdam 3089 JN, Netherlands; Email
Address [email protected]; Additional Sanctions Information - Subject to Secondary Sanctions; Telephone +31 010-4951863; Telephone +31 10-
4360037; Fax +31 10-4364096 [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NAFTIRAN INTERTRADE CO. (NICO) LIMITED (a.k.a. NAFT IRAN INTERTRADE COMPANY LTD; a.k.a. NAFTIRAN INTERTRADE COMPANY
(NICO); a.k.a. NAFTIRAN INTERTRADE COMPANY LTD; a.k.a. NICO), 41, 1st Floor, International House, The Parade, St Helier JE2 3QQ, Jersey;
Petro Pars Building, Saadat Abad Ave, No 35, Farhang Blvd, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions; all
offices worldwide [IRAN] (Linked To: NIOC INTERNATIONAL AFFAIRS (LONDON) LIMITED).
NAFTIRAN INTERTRADE CO. (NICO) SARL (a.k.a. NICO), 6, Avenue de la Tour-Haldimand, Pully, VD 1009, Switzerland; Additional Sanctions
Information - Subject to Secondary Sanctions; all offices worldwide [IRAN].
NAFTIRAN TRADING SERVICES CO. (NTS) LIMITED, 47 Queen Anne Street, London W1G 9JG, United Kingdom; 6th Floor NIOC Ho, 4 Victoria St,
London SW1H 0NE, United Kingdom; Additional Sanctions Information - Subject to Secondary Sanctions; UK Company Number 02600121 (United
Kingdom); all offices worldwide [IRAN].
NARENJESTAN HOTEL AND BUILDING DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
NARI SHIPPING AND CHARTERING GMBH & CO. KG (a.k.a. NARI SHIPPING AND CHARTERING GMBH AND CO. KG), Schottweg 5, Hamburg
22087, Germany; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License No. HRA102485 [IRAN].
NATIONAL INDUSTRIES AND MINING DEVELOPMENT COMPANY, Number 55, Pardis Street, N. Shirazi Street, Molla-Sadra Street, Vanak Square,
Tehran, Iran; Website www.nimidco.com; Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number 323908 (Iran)
[SDGT] [IFSR] (Linked To: TOSE-E MELLI GROUP INVESTMENT COMPANY).
NATIONAL IRANIAN OIL COMPANY (a.k.a. NIOC), Hafez Crossing, Taleghani Avenue, P.O. Box 1863 and 2501, Tehran, Iran; National Iranian Oil
Company Building, Taleghani Avenue, Hafez Street, Tehran, Iran; Website www.nioc.ir; Additional Sanctions Information - Subject to Secondary
Sanctions; all offices worldwide [IRAN] [IFCA].
NATIONAL IRANIAN OIL COMPANY PTE LTD, 7 Temasek Boulevard #07-02, Suntec Tower One 038987, Singapore; Additional Sanctions Information -
Subject to Secondary Sanctions; Registration ID 199004388C (Singapore); all offices worldwide [IRAN].
NATIONAL IRANIAN TANKER COMPANY (a.k.a. NITC), NITC Building, 67-88, Shahid Atefi Street, Africa Avenue, Tehran, Iran; Website www.nitc.co.ir;
Email Address [email protected]; alt. Email Address [email protected]; Additional Sanctions Information - Subject to Secondary Sanctions;
Telephone (98)(21)(66153220); Telephone (98)(21)(23803202); Telephone (98)(21)(23803303); Telephone (98)(21)(66153224); Telephone (98)(21)
(23802230); Telephone (98)(9121115315); Telephone (98)(9128091642); Telephone (98)(9127389031); Fax (98)(21)(22224537); Fax (98)(21)
(23803318); Fax (98)(21)(22013392); Fax (98)(21)(22058763) [IRAN] [IFCA].
NATIONAL IRANIAN TANKER COMPANY LLC (a.k.a. NATIONAL IRANIAN TANKER COMPANY LLC SHARJAH BRANCH; a.k.a. NITC SHARJAH), Al
Wahda Street, Street No. 4, Sharjah, United Arab Emirates; P.O. Box 3267, Sharjah, United Arab Emirates; Website http://nitcsharjah.com/index.html;
Additional Sanctions Information - Subject to Secondary Sanctions; Telephone +97165030600; Telephone + 97165749996; Telephone +971506262258;
Fax +97165394666; Fax +97165746661 [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NATIONAL PETROCHEMICAL COMPANY (a.k.a. "NPC"), No. 104, North Sheikh Bahaei Blvd., Molla Sadra Ave., Tehran, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions; all offices worldwide [IRAN].
NATIONWIDE SHIPPING LTD, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information -
Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NEGIN KISH INTERNATIONAL SAHEL AND FARASAHEL DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions
[IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
NEW AGE SHIPPING LIMITED (a.k.a. NEW AGE SHIPPING LTD-BZE), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran,
Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NEYRIZ STEEL, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
NICO ENGINEERING LIMITED, 41, 1st Floor, International House, The Parade, St. Helier JE2 3QQ, Jersey; Additional Sanctions Information - Subject
to Secondary Sanctions; Registration ID 75797 (Jersey); all offices worldwide [IRAN].
NINTH OCEAN GMBH & CO. KG (a.k.a. NINTH OCEAN GMBH AND CO. KG), Schottweg 5, Hamburg 22097, Germany; Additional Sanctions
Information - Subject to Secondary Sanctions; Trade License No. HRA 102565 [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 15/83
NIOC INTERNATIONAL AFFAIRS (LONDON) LIMITED, NIOC House, 4 Victoria Street, London SW1H 0NE, United Kingdom; Additional Sanctions
Information - Subject to Secondary Sanctions; UK Company Number 02772297 (United Kingdom); all offices worldwide [IRAN].
NOOR ENERGY (MALAYSIA) LTD., Labuan, Malaysia; Additional Sanctions Information - Subject to Secondary Sanctions; Company Number LL08318
[IRAN].
NOURI PETROCHEMICAL COMPANY (a.k.a. BORZUYEH PETROCHEMICAL COMPANY; a.k.a. NOURI PETROCHEMICAL COMPLEX), Pars Special
Economic Energy Zone, Assaluyeh Port, Bushehr, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
NOVIN ENERGY COMPANY (a.k.a. ENERGY NOVIN COMPANY; a.k.a. ENERGY NOVIN CORPORATION; a.k.a. NOVIN ENERGY; a.k.a. NOVIN
ENERGY CORPORATION), Tehran, Iran; 1st Shaghayegh Bld., North Kargar St., Tehran, Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
NOVIN PARS MINERAL EXPLORATION AND MINING ENGINEERING COMPANY (a.k.a. NOVIN KHARA; a.k.a. NOVIN KHARA MINERAL MINING
EXTRACTION COMPANY; a.k.a. NOVIN PARS MINERAL EXPLORATION AND MINING COMPANY; a.k.a. NOVIN PARS MINERAL MINING
COMPANY; a.k.a. "ASKAM"; a.k.a. "ESKAM"; a.k.a. "MINERAL MINING EXTRACTION COMPANY"; a.k.a. "SKAM"), Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
NPC INTERNATIONAL LIMITED (a.k.a. N P C INTERNATIONAL LTD; a.k.a. NPC INTERNATIONAL COMPANY), 5th Floor NIOC House, 4 Victoria
Street, London SW1H 0NE, United Kingdom; Additional Sanctions Information - Subject to Secondary Sanctions; UK Company Number 02696754
(United Kingdom); all offices worldwide [IRAN].
NUCLEAR INDUSTRY EXPLORATION AND RAW MATERIALS PRODUCTION COMPANY (a.k.a. EXPLORATION AND NUCLEAR RAW MATERIAL
PRODUCTION COMPANY; a.k.a. EXPLORATION AND NUCLEAR RAW MATERIALS PRODUCTION COMPANY; a.k.a. "EMKA"), Iran; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: TAMAS COMPANY).
NUCLEAR POWER PRODUCTION AND DEVELOPMENT COMPANY OF IRAN (a.k.a. NUCLEAR POWER PRODUCTION AND DEVELOPMENT
HOLDING COMPANY; a.k.a. "NPPD"), No. 8, Tandis St., Africa Ave., Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions
[IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
NUCLEAR SCIENCE AND TECHNOLOGY RESEARCH INSTITUTE (a.k.a. NUCLEAR SCIENCES AND TECHNOLOGIES RESEARCH INSTITUTE;
a.k.a. "NSTRI"), North Kargar Street, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: ATOMIC
ENERGY ORGANIZATION OF IRAN).
OCEAN CAPITAL ADMINISTRATION GMBH, Schottweg 5, Hamburg 22087, Germany; Additional Sanctions Information - Subject to Secondary
Sanctions; Trade License No. HRA 92501 [IRAN].
OFOQ SAZEH PAYAH, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
OGHYANOUS KHOROSHAN KISH (a.k.a. KHOROSHAN MARITIME COMPANY; a.k.a. OGHYANOUS-E KHOROUSHAN-E KISH SHIPPING LINES),
Unit 5, 9th Street 2, Ahmad Ghasir Avenue, PO Box 19635-1114, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions
[IRAN].
OIL INDUSTRY INVESTMENT COMPANY (a.k.a. "O.I.I.C."), No. 83, Sepahbod Gharani Street, Tehran, Iran; Website http://www.oiic-ir.com; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN].
OMID BONYAN DAY INSURANCE SERVICES, Vozara Street, Tehran, Iran; Website http://omiddayins.ir; Additional Sanctions Information - Subject to
Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
OMID REY CIVIL & CONSTRUCTION COMPANY (a.k.a. OMID DEVELOPMENT AND CONSTRUCTION; a.k.a. OMID REY CIVIL AND
CONSTRUCTION COMPANY; a.k.a. OMID REY RENOVATION AND DEVELOPMENT CO.); Website http://www.omidrey.com; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN].
OMRAN VA MASKAN ABAD DAY COMPANY, No. 52, Shariati Street, Shahid Mousavi Street, Tehran, Iran; Website www.omaday.ir; Additional
Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
ONE CLASS PROPERTIES (PTY) LTD. (a.k.a. ONE CLASS INCORPORATED), Cape Town, South Africa; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN].
ONE VISION INVESTMENTS 5 (PTY) LTD. (a.k.a. ONE VISION 5), 3rd Floor, Tygervalley Chambers, Bellville, Cape Town 7530, South Africa; Canal
Walk, P.O. Box 17, Century City, Milnerton 7446, South Africa; Additional Sanctions Information - Subject to Secondary Sanctions; Registration ID
2002/022757/07 (South Africa) [IRAN].
ONERBANK ZAO (a.k.a. EFTEKHAR BANK; a.k.a. HONOR BANK; a.k.a. HONORBANK; a.k.a. HONORBANK ZAO; a.k.a. ONER BANK; a.k.a.
ONERBANK; a.k.a. ONER-BANK), Ulitsa Klary Tsetkin 51, Minsk 220004, Belarus; SWIFT/BIC HNRBBY2X; Registration ID 807000227 (Belarus)
issued 16 Oct 2009; all offices worldwide [IRAN].
P.C.C. (SINGAPORE) PRIVATE LIMITED (a.k.a. P.C.C. SINGAPORE BRANCH; a.k.a. PCC SINGAPORE PTE LTD), 78 Shenton Way, #08-02 079120,
Singapore; 78 Shenton Way, 26-02A Lippo Centre 079120, Singapore; Additional Sanctions Information - Subject to Secondary Sanctions; Registration
ID 199708410K (Singapore); all offices worldwide [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 16/83
PACIFIC OCEAN SHIPPING LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
PACIFIC SHIPPING AND TRANSPORTATION LIMITED (a.k.a. PACIFIC SHIPPING & TRANS; a.k.a. PACIFIC SHIPPING AND TRANS), East Shahid
Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked
To: NATIONAL IRANIAN TANKER COMPANY).
PALM SERVICE LIMITED (a.k.a. "PALM SERVICE LTD"), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
PARDIS INVESTMENT COMPANY (a.k.a. SHERKAT-E SARMAYEGOZARI-E PARDIS), Iran; Unit D4 and C4, 4th Floor, Building 29 Africa, Corner of
25th Street, Africa Boulevard, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
PARS GHA'EM GOSTAR, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
PARS INTERNATIONAL INDUSTRY DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
PARS ISOTOPE COMPANY, No. 88, West 23rd St. Azadegan Blvd. South Sheykh Bahaie Ave., Tehran, Iran; Website http://www.parsisotope.com;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
PARS MCS (a.k.a. PARS MCS CO.; a.k.a. PARS MCS COMPANY), 2nd Floor, No. 4, Sasan Dead End, Afriqa Avenue, After Esfandiar, Crossroads,
Tehran, Iran; No. 5 Sasan Alley, Atefi Sharghi St., Afrigha Boulevard, Tehran, Iran; Oshtorjan Industrial Zone, Zob-e Ahan Highway, Isafahan, Iran;
Website http://www.parsmcs.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
PARS NICKEL KARAN KABIR, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
PARS OIL AND GAS COMPANY (a.k.a. POGC), No. 133, Side of Parvin Etesami Alley, opposite Sazman Ab - Dr. Fatemi Avenue, Tehran, Iran; No. 1
Parvin Etesami Street, Fatemi Avenue, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
PARS OIL CO. (a.k.a. PARS OIL; a.k.a. SHERKAT NAFT PARS SAHAMI AAM), Iran; No. 346, Pars Oil Company Building, Modarres Highway, East
Mirdamad Boulevard, Tehran 1549944511, Iran; Postal Box 14155-1473, Tehran 159944511, Iran; Website http://www.parsoilco.com; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN].
PARS PAIDAR SANAT NOVIN, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
PARS PETROCHEMICAL COMPANY, Pars Special Economic Energy Zone, PO Box 163-75391, Assaluyeh, Bushehr, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN].
PARS PETROCHEMICAL SHIPPING COMPANY, 1st Floor, No. 19, Shenasa Street, Vali E Asr Avenue, Tehran, Iran; Website www.parsshipping.com;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
PARS SAZEH ENGINEERING AND CONSTRUCTION, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
PARSIAN OIL AND GAS DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
PARSIAN RAIL TRANSPORT DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
PASARGAD BANK (a.k.a. BANK-E PASARGAD), Valiasr St., Mirdamad St., No. 430, Tehran, Iran; SWIFT/BIC BKBPIRTH [IRAN].
PAYANDEH JAAM ELECTRICITY ENERGY, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
PAYVAR ANDISH, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
PERSIA HORMOZ SHIP REPAIR YARD COMPANY PJS (a.k.a. PERSIA HORMOZ SHIP REPAIRS; a.k.a. PERSIA HORMOZ SHIPYARD), 37 Km,
West Bandar Abbas Road, Bandar Abbas 791453859, Iran; Website www.persiahormoz.com; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN].
PERSIA INTERNATIONAL BANK PLC, 6 Lothbury, EC2R 7HH, London, United Kingdom; PO Box 119871, No 209, 2nd Floor, Tower II, Al Fattan
Currency House, Dubai International Financial Centre, Dubai, United Arab Emirates; SWIFT/BIC PIBPGB2L; Website www.persiabank.co.uk; Additional
Sanctions Information - Subject to Secondary Sanctions; Registration Number 4218020 (United Kingdom); All Offices Worldwide [SDGT] [IFSR] (Linked
To: BANK MELLAT).
PERSIA OIL & GAS INDUSTRY DEVELOPMENT CO. (a.k.a. PERSIA OIL AND GAS INDUSTRY DEVELOPMENT CO.; a.k.a. TOSE SANAT-E NAFT
VA GAS PERSIA), 7th Floor, No. 346, Mirdamad Avenue, Tehran, Iran; Ground Floor, No. 14, Saba Street, Africa Boulevard, Tehran, Iran; Website
http://www.pogidc.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 17/83
PERSIAN GULF SABZ KARAFARINAN (a.k.a. PERSIAN GULF KHATAR-PAZIR INVESTMENT COMPANY), No. 17, Fifth Floor, 17th Alley, Vozara
Street, Tehran, Iran; Website www.persiangulffvc.com; Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To:
TOSE-E MELLI GROUP INVESTMENT COMPANY).
PERSIAN GULF SHIPPING LINES LTD (a.k.a. KHALIJ-E FARS (PERSIAN GULF) SHIPPING LINES; a.k.a. "PGSL"), Strovolos Center, Flat No. 204,
Floor No. 2, Strovolou 77, Nicosia 2018, Cyprus; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License No. C334268
(Cyprus) [IRAN].
PETRO ENERGY INTERTRADE COMPANY, Dubai, United Arab Emirates; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
PETRO ROYAL FZE, United Arab Emirates; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
PETRO SUISSE INTERTRADE COMPANY SA, 6 Avenue de la Tour-Haldimand, Pully 1009, Switzerland; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN].
PETROCHEMICAL COMMERCIAL COMPANY (U.K.) LIMITED (a.k.a. PCC (UK); a.k.a. PCC UK; a.k.a. PCC UK LTD), 4 Victoria Street, London SW1H
0NE, United Kingdom; Additional Sanctions Information - Subject to Secondary Sanctions; UK Company Number 02647333 (United Kingdom); all
offices worldwide [IRAN].
PETROCHEMICAL COMMERCIAL COMPANY FZE (a.k.a. PCC FZE), 1703, 17th Floor, Dubai World Trade Center Tower, Sheikh Zayed Road, Dubai,
United Arab Emirates; Office No. 99-A, Maker Tower "F" 9th Floor Cutte Pavade, Colabe, Mumbai 700005, India; Additional Sanctions Information -
Subject to Secondary Sanctions; all offices worldwide [IRAN].
PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL (a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LIMITED;
a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LTD; a.k.a. PETROCHEMICAL TRADING COMPANY LIMITED; a.k.a.
"PCCI"), 41, 1st Floor, International House, The Parade, St. Helier JE2 3QQ, Jersey; Ave. 54, Yimpash Business Center, No. 506, 507, Ashkhabad
744036, Turkmenistan; P.O. Box 261539, Jebel Ali, Dubai, United Arab Emirates; No. 21 End of 9th St, Gandi Ave, Tehran, Iran; 21, Africa Boulevard,
Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Registration ID 77283 (Jersey); all offices worldwide [IRAN].
PETROIRAN DEVELOPMENT COMPANY (PEDCO) LIMITED (a.k.a. PETRO IRAN DEVELOPMENT COMPANY; a.k.a. "PEDCO"), 41, 1st Floor,
International House, The Parade, St. Helier JE2 3QQ, Jersey; National Iranian Oil Company - PEDCO, P.O. Box 2965, Al Bathaa Tower, 9th Floor, Apt.
905, Al Buhaira Corniche, Sharjah, United Arab Emirates; P.O. Box 15875-6731, Tehran, Iran; No. 22, 7th Lane, Khalid Eslamboli Street, Shahid
Beheshti Avenue, Tehran, Iran; No. 102, Next to Shahid Amir Soheil Tabrizian Alley, Shahid Dastgerdi (Ex Zafar) Street, Shariati Street, Tehran
19199/45111, Iran; Kish Harbour, Bazargan Ferdos Warehouses, Kish Island, Iran; Additional Sanctions Information - Subject to Secondary Sanctions;
Registration ID 67493 (Jersey); all offices worldwide [IRAN].
PETROPARS INTERNATIONAL FZE (a.k.a. PPI FZE), P.O. Box 72146, Dubai, United Arab Emirates; Additional Sanctions Information - Subject to
Secondary Sanctions; all offices worldwide [IRAN].
PETROPARS LTD. (a.k.a. PETROPARS LIMITED; a.k.a. "PPL"), No. 35, Farhang Blvd., Saadat Abad, Tehran, Iran; Calle La Guairita, Centro
Profesional Eurobuilding, Piso 8, Oficina 8E, Chuao, Caracas 1060, Venezuela; P.O. Box 3136, Road Town, Tortola, Virgin Islands, British; Additional
Sanctions Information - Subject to Secondary Sanctions; all offices worldwide [IRAN].
PETROPARS UK LIMITED, 47 Queen Anne Street, London W1G 9JG, United Kingdom; Additional Sanctions Information - Subject to Secondary
Sanctions; UK Company Number 03503060 (United Kingdom); all offices worldwide [IRAN].
POLINEX GENERAL TRADING LLC, Health Care City, Umm Hurair Rd., Oud Mehta Offices, Block A, 4th Floor 420, Dubai, United Arab Emirates;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
POLYNAR COMPANY, No. 58, St. 14, Qanbarzadeh Avenue, Resalat Highway, Tehran, Iran; Website http://www.polynar.com; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN].
POST BANK OF IRAN (a.k.a. POSTBANK), 237 Motahari Avenue, Tehran 1587618118, Iran; Kouh-e Nour Street, Shahid Motahari Avenue, Tehran
1587618111, Iran; SWIFT/BIC PBIRIRTH; Website www.postbank.ir; Additional Sanctions Information - Subject to Secondary Sanctions; All Offices
Worldwide [IRAN] [NPWMD] [IFSR] (Linked To: BANK SEPAH).
POUYA TAMIN KISH (a.k.a. POUYA TAMIN KISH CO.; a.k.a. POUYA TAMIN KISH OIL & GAS CO; a.k.a. POUYA TAMIN KISH OIL AND GAS CO;
a.k.a. "PTK"), Block EX6, In front of IRAN Blvd., Kish Island, Iran; Website http://nitcshipping.com; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
POUYAN TABAAN ENERGY, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
POWER PLANT EQUIPMENT MANUFACTURING COMPANY (a.k.a. SATNA COMPANY; a.k.a. "POWERPLANT EQUIPMENT MANUFACTURING
COMPANY"; a.k.a. "SATNA"), Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY
ORGANIZATION OF IRAN).
PROTON PETROCHEMICALS SHIPPING LIMITED (a.k.a. PROTON SHIPPING CO; a.k.a. "PSC"), Diagoras House, 7th Floor, 16 Panteli Katelari
Street, Nicosia 1097, Cyprus; Additional Sanctions Information - Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 18/83
QOM ENERGY GENERATION GOSTAR, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
RAAHBAR COMPUTER RESOURCES MANAGEMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To:
GHADIR INVESTMENT COMPANY).
RAAHBAR INFORMATICS SERVICES (a.k.a. RAAHBAR KHADAMAT INFORMATIC), Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
RAAHBAR SARIR INTEGRATED TRACKING SYSTEMS INC, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked
To: GHADIR INVESTMENT COMPANY).
RADIATION APPLICATIONS DEVELOPMENT COMPANY (a.k.a. RADIATION APPLICATIONS DEVELOPMENT HOLDING COMPANY; a.k.a. "RAD";
a.k.a. "RADIATION APPLICATIONS"), Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: ATOMIC
ENERGY ORGANIZATION OF IRAN).
RAHBARAN OMID DARYA SHIP MANAGEMENT CO. (a.k.a. RAHBARAN-E OMID-E DARYA SHIP MANAGEMENT; a.k.a. ROD SHIP MANAGEMENT
CO; a.k.a. RODSM; f.k.a. SOROUSH SARZAMIN ASATIR SHIP MANAGEMENT CO.; f.k.a. SOROUSH SARZAMIN ASATIR SSA; f.k.a. SSA SHIP
MANAGEMENT CO.), Unit 5, 9th Street 2, Ahmad Ghasir Avenue, PO Box 19635-1114, Tehran, Iran; No. 5, Shabnam Alley, Ghaem Magham Farahani
Street, Shahid Motahari Avenue, Tehran, Iran; Website www.rodsmc.com; Additional Sanctions Information - Subject to Secondary Sanctions;
Registration Number 341563 (Iran) [IRAN].
RAILCOM RAAHBAR CO., Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
RASTIN KHADAMAT PARSIAN COMPANY (a.k.a. PARSIAN TECHNOLOGY SUPPORT COMPANY), Iran; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
REY INVESTMENT COMPANY, 2nd and 3rd Floors, No. 14, Saba Boulevard, After Esfandiar Crossroad, Africa Boulevard, Tehran 1918973657, Iran;
Website http://www.rey-co.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
REY NIRU ENGINEERING COMPANY (a.k.a. REY NIROO ENGINEERING COMPANY); Website http://www.reyniroo.com; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN].
REYCO GMBH. (a.k.a. REYCO GMBH GERMANY), Karlstrasse 19, Dinslaken, Nordrhein-Westfalen 46535, Germany; Additional Sanctions Information
- Subject to Secondary Sanctions [IRAN].
RISHMAK PRODUCTIVE & EXPORTS COMPANY (a.k.a. RISHMAK COMPANY; a.k.a. RISHMAK EXPORT AND MANUFACTURING P.J.S.; a.k.a.
RISHMAK PRODUCTION AND EXPORT COMPANY; a.k.a. RISHMAK PRODUCTIVE AND EXPORTS COMPANY; a.k.a. SHERKAT-E TOLID VA
SADERAT-E RISHMAK), Rishmak Cross Rd., 3rd Km. of Amir Kabir Road, Shiraz 71365, Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN].
ROYAL ARYA CO. (a.k.a. ARIA ROYAL CONSTRUCTION COMPANY), Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
ROYAY-E ROZ KISH INVESTMENT COMPANY, No. 132, First Floor, Unit 1, South Dibagi Street, Ekhtiyariyeh, Tehran, Iran; Website
www.daybankinvest.com; Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
SADAF PETROCHEMICAL ASSALUYEH COMPANY (a.k.a. SADAF ASALUYEH CO.; a.k.a. SADAF CHEMICAL ASALUYEH COMPANY; a.k.a.
SADAF PETROCHEMICAL ASSALUYEH INVESTMENT SERVICE), Assaluyeh, Iran; South Pars Special Economy/Energy Zone, Iran; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN].
SAFIRAN PAYAM DARYA SHIPPING COMPANY (a.k.a. "SAPID"), Asseman Tower, Pasdaran Street, Tehran, Iran; Website www.sapidshpg.com;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
SAKHTEMAN INTERNATIONAL DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
SAMAN BANK (a.k.a. BANK-E SAMAN), Vali Asr. St. No. 3, Before Vey Park intersection, corner of Tarakesh Dooz St. , Tehran, Iran; SWIFT/BIC
SABCIRTH [IRAN].
SAMAN SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SAMBOUK SHIPPING FZC, FITCO Building No. 3, Office 101, 1st Floor, P.O. Box 50044, Fujairah, United Arab Emirates; Office 1202, Crystal Plaza,
PO Box 50044, Buhaira Corniche, Sharjah, United Arab Emirates; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
SARMAYEH BANK (a.k.a. BANK-E SARMAYEH), Sepahod Gharani No. 24, Corner of Arak St., Tehran, Iran [IRAN].
SARV SHIPPING COMPANY LIMITED, 198 Old Bakery Street, Valletta VLT 1455, Malta; Additional Sanctions Information - Subject to Secondary
Sanctions; Telephone (356)(21241232) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SEPAHAN CEMENT (a.k.a. SIMAN SEPAHAN), Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 19/83
SEPAHAN CEMENT CONCRETE PRODUCTS (a.k.a. FARAVARDEHAYE BOTONI SIMAN SEPAHAN), Iran; Additional Sanctions Information - Subject
to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
SEPAHAN CEMENT INVESTMENT (a.k.a. SARMAYE GOZARI SIMAN SEPAHAN), Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
SEPAHAN CEMENT PAKAT-SAZI SHAFAGH (a.k.a. PAKAT SAZI SHAFAGH SIMAN SEPAHAN), Iran; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
SEPAHAN CEMENT RAHNAVARD PRODUCTS TRANSPORTATION (a.k.a. HAML VA NAGHL KALAHAYE RAHNAVARD SIMAN SEPAHAN), Iran;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
SEPEHR IRANIAN INSURANCE SERVICES, Iran [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
SEPEHR MASHAHD CEMENT TRANSPORTATION (a.k.a. HAML VA NAGHL SEPEHR SIMAN MASHHAD), Iran; Additional Sanctions Information -
Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
SEPID SHIPPING COMPANY LIMITED, 198 Old Bakery Street, Valletta VLT 1455, Malta; Additional Sanctions Information - Subject to Secondary
Sanctions; Telephone (356)(21241232) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SHAHID TONDGOOYAN PETROCHEMICAL COMPANY (a.k.a. SHAHID TONDGUYAN PETROCHEMICAL COMPANY), Petrochemical Special
Economic Zone (PETZONE), Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
SHARQ CEMENT (a.k.a. SIMAN-E SHARGH), Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
SHARQ CEMENT INDUSTRIAL LIMESTONE (a.k.a. AHAK-E SANATI SIMAN SHARGH), Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
SHARQ CEMENT MANUFACTURERS (a.k.a. FARAVARDEHAYE SIMAN SHARGH), Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
SHARQ COALMINES (a.k.a. MA'ADEN-E ZOGHAL SANG SHARGH), Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN]
(Linked To: GHADIR INVESTMENT COMPANY).
SHARQ WHITE CEMENT (a.k.a. SIMAN'E SEFID SHARGH), Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked
To: GHADIR INVESTMENT COMPANY).
SHAZAND PETROCHEMICAL COMPANY (a.k.a. AR.P.C.; a.k.a. ARAK PETROCHEMICAL COMPANY; a.k.a. SHAZAND PETROCHEMICAL
CORPORATION), No. 68, Taban St., Vali Asr Ave., Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
SHIPPING COMPUTER SERVICES COMPANY (a.k.a. SCSCO), No. 37, Asseman Shahid Sayyad Shirazeesq, Pasdaran Ave, PO Box 1587553-1351,
Tehran, Iran; Website www.scsco.net; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
SHIPPING WELFARE SERVICES INSTITUTE (a.k.a. IRISL CLUB; a.k.a. ISLAMIC REPUBLIC OF IRAN SHIPPING LINES COMFORT SERVICES;
a.k.a. MARITIME WELFARE SERVICES INSTITUTE), Number 63, East Shahid Tajrlu Street, Shahid Tajrlu Square, Shian, Iran; Website
www.irislclub.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
SHIRAZ PARS FARAYAND OIL REFINERY, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
SHOMAL CEMENT COMPANY, No. 269, Shahid Beheshti Street, Tehran, Iran; Website www.shomalcement.com; Additional Sanctions Information -
Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: CEMENT INDUSTRY INVESTMENT AND DEVELOPMENT COMPANY).
SIMA GENERAL TRADING CO FZE (a.k.a. SIMA GENERAL TRADING & INDUSTRIALS FOR BUILDING MATERIAL CO FZE), Office No. 703 Office
Tower, Twin Tower, Baniyas Rd., Deira, P.O. Box 49754, Dubai, United Arab Emirates; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN].
SIMA SHIPPING COMPANY LIMITED, 198 Old Bakery Street, Valletta VLT 1455, Malta; Additional Sanctions Information - Subject to Secondary
Sanctions; Telephone (356)(21241232) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SINA SHIPPING COMPANY LIMITED, 198 Old Bakery Street, Valletta VLT 1455, Malta; Additional Sanctions Information - Subject to Secondary
Sanctions; Telephone (356)(21241232) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SOUTH ALUMINUM, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
SOUTH IRAN DARYABAN KISH, Kish, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
SOUTH SHIPPING LINES - IRAN LINE (a.k.a. KASHTIRANI-E JONOUB KHAT-E IRAN), No 119 Shabnam Alley, Ghaem Magham Street, Tehran, Iran;
Website www.sslil.net; IFCA Determination - Involved in the Shipping Sector; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN]
[IFCA].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 20/83
SPEED TRANSPORTATION LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SPRING SHIPPING LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information -
Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
STAR SHIP MANAGEMENT LIMITED (a.k.a. STAR SHIP MANAGEMENT LTD-BZE), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-
4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SWISS MANAGEMENT SERVICES SARL, 28C, Route de Denges, Lonay 1027, Switzerland; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN].
SYNERGY GENERAL TRADING FZE, Sharjah - Saif Zone, Sharjah Airport International Free Zone, United Arab Emirates; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN].
TABRIZ PETROCHEMICAL COMPANY, Off Km 8, Azarshahr Road, Kojuvar Road, Tabriz, Iran; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN].
TADBIR BROKERAGE COMPANY (a.k.a. SHERKAT-E KARGOZARI-E TADBIRGARAN-E FARDA; a.k.a. TADBIRGARAN FARDA BROKERAGE
COMPANY; a.k.a. TADBIRGARAN-E FARDA BROKERAGE COMPANY; a.k.a. TADBIRGARANE FARDA MERCANTILE EXCHANGE CO.), Unit C2,
2nd Floor, Building No. 29, Corner of 25th Street, After Jahan Koudak, Cross Road Africa Street, Tehran 15179, Iran; Website
http://www.tadbirbroker.com; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
TADBIR CONSTRUCTION DEVELOPMENT COMPANY (a.k.a. GORUH-E TOSE-E SAKHTEMAN-E TADBIR; a.k.a. TADBIR BUILDING EXPANSION
GROUP; a.k.a. TADBIR HOUSING DEVELOPMENT GROUP), Block 1, Mehr Passage, 4th Street, Iran Zamin Boulevard, Shahrak Qods, Tehran, Iran;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
TADBIR ECONOMIC DEVELOPMENT GROUP (a.k.a. TADBIR GROUP), 16 Avenue Bucharest, Tehran, Iran; Additional Sanctions Information - Subject
to Secondary Sanctions [IRAN].
TADBIR ENERGY DEVELOPMENT GROUP CO., 6th Floor, Mirdamad Avenue, No. 346, Tehran, Iran; Website http://www.tadbirenergy.com; Additional
Sanctions Information - Subject to Secondary Sanctions [IRAN].
TADBIR INVESTMENT COMPANY, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
TAKHTEH SHAHID BA HONAR, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
TAMAS COMPANY (a.k.a. NUCLEAR FUEL AND RAW MATERIALS PRODUCTION COMPANY; a.k.a. RAW MATERIALS AND NUCLEAR FUEL
PRODUCTION COMPANY; a.k.a. "TAMAS"), Shahid Chamran Building, North Kargar Street, Tehran, Iran; Additional Sanctions Information - Subject to
Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
TARABAR-GOROUS TRUST TRANSPORTATION (a.k.a. HAML VA NAGHL ETEMAAD TARABARGROUS), Iran; Additional Sanctions Information -
Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
TARGET TRANSPORTATION LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
TAT BANK (a.k.a. BANK-E TAT), Shahid Ahmad Ghasir (Bocharest), Shahid Ahmadian (15th) St., No. 1, Tehran, Iran; No. 1 Ahmadian Street, Bokharest
Avenue, Tehran, Iran; SWIFT/BIC TATBIRTH [IRAN].
TC SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Subject to Secondary Sanctions; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
TEJARAT GOSTAR FARDAD, No. 13, First Floor, Unit 1, Shahab (11th) Street, Gandy Street, Tehran, Iran; No. 1/2, 2nd Floor, Yavari Alley, Across from
Niyavaran Commercial Complex, Niyaravan, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked
To: DAY BANK).
TEJARAT PAYDAR PAYMAN DEVELOPMENT, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR
INVESTMENT COMPANY).
THE NUCLEAR REACTORS FUEL COMPANY (a.k.a. "SOOREH"; a.k.a. "SUREH"), End of North Kargar Street, Shahid Abtahi Street, (20th), #61,
Tehran, Iran; Esfahan Complex Khalije Fars Blvd., 20 km southeast of Esfahan, P.O. Box: 81465-1957, Iran; Additional Sanctions Information - Subject
to Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
TISA KISH, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
TOSE-E DIDAR IRANIAN HOLDING COMPANY, No. 1, Moqaddas Alley, Shahid Ahmad Qasir (Bukharest) Street, Tehran, Iran; Website https://tdday.ir;
Additional Sanctions Information - Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
TOSE-E DONYA SHAHR KOHAN COMPANY, No. 52, 4th Floor, Mousavivand Street, Shariati Street, Tehran, Iran; Additional Sanctions Information -
Subject to Secondary Sanctions [SDGT] [IFSR] (Linked To: DAY BANK).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 21/83
TOSEE EQTESAD AYANDEHSAZAN COMPANY (a.k.a. TEACO; a.k.a. TOSEE EGHTESAD AYANDEHSAZAN COMPANY), 39 Gandhi Avenue,
Tehran 1517883115, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN].
TOSE-E MELLI GROUP INVESTMENT COMPANY (f.k.a. BANK MELLI IRAN INVESTMENT COMPANY; a.k.a. IRAN MELLI BANK INVESTMENT
COMPANY; a.k.a. NATIONAL DEVELOPMENT AND INVESTMENT GROUP; a.k.a. TOSEE MELLI GROUP INVESTMENT COMPANY; a.k.a. TOSE-E
MELLI GROUP INVESTMENT COMPANY PUBLIC SHAREHOLDING COMPANY; a.k.a. "TMGIC"), 2 Nader Alley, After Dr Vali e Asr Avenue, Tehran
15116, Iran; PO Box 15875-3898, Iran; Building 89, Khoddami Street, Vanak, Tehran 53158753898, Iran; Number 89, Shahid Khodami Street, After
Kurdistan Bridge, Vanak Square, Iran; Vank Square, Shahid Khademi Street, after Kurdistan Bridge, No. 89, Tehran 1958698856, Iran; Website
www.bmiic.ir; alt. Website www.en.tmgic.ir; Additional Sanctions Information - Subject to Secondary Sanctions; National ID No. 10101339590 (Iran);
Registration Number 89584 (Iran) [SDGT] [IFSR] (Linked To: BANK MELLI IRAN).
TOSE-E MELLI INVESTMENT COMPANY (a.k.a. NATIONAL DEVELOPMENT INVESTMENT COMPANY; a.k.a. TOSEE MELLI INVESTMENT
COMPANY), No. 1 St.North Didar.Blv Haghani, Tehran, Iran; Number 89, Shahid Khodami Street, After Kurdistan Bridge, Vanak Square, Tehran, Iran;
Website www.tmico.ir; Additional Sanctions Information - Subject to Secondary Sanctions; Registration Number 208669 (Iran) [SDGT] [IFSR] (Linked
To: TOSE-E MELLI GROUP INVESTMENT COMPANY).
TOSEE TAAVON BANK (a.k.a. BANK-E TOSE'E TA'AVON; a.k.a. COOPERATIVE DEVELOPMENT BANK), Mirdamad Blvd., North East Corner of
Mirdamad Bridge, No. 271, Tehran, Iran [IRAN].
TOURISM BANK (a.k.a. BANK-E GARDESHGARI), Vali Asr St., above Vey Park, Shahid Fiazi St., No. 51, first floor, Tehran, Iran [IRAN].
TWELFTH OCEAN ADMINISTRATION GMBH, Schottweg 5, Hamburg 22087, Germany; Additional Sanctions Information - Subject to Secondary
Sanctions; Trade License No. HRB94573 [IRAN].
TWELFTH OCEAN GMBH & CO. KG (a.k.a. TWELFTH OCEAN GMBH AND CO. KG), Schottweg 5, Hamburg 22087, Germany; Additional Sanctions
Information - Subject to Secondary Sanctions; Trade License No. HRA 102506 [IRAN].
UNIVERSAL SHIPPING AND TRANSPORTATION LIMITED (a.k.a. UNIVERSAL SHIPPING & TRANS; a.k.a. UNIVERSAL SHIPPING AND TRANS),
East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
UNIVERSE SHIPPING LIMITED, East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran; Additional Sanctions Information -
Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
URANIUM PROCESSING AND NUCLEAR FUEL COMPANY (a.k.a. FATSA COMPANY; a.k.a. URANIUM PROCESSING AND NUCLEAR FUEL
COMPANY OF IRAN; a.k.a. URANIUM PROCESSING AND NUCLEAR FUEL PRODUCTION COMPANY; a.k.a. "FATSA"), Iran; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN] (Linked To: ATOMIC ENERGY ORGANIZATION OF IRAN).
VALFAJR SHIPPING COMPANY PJS (a.k.a. VALFAJR 8 SHIPPING CO.; a.k.a. VALFAJR SHIPPING CO.; a.k.a. VALFAJR SHIPPING LINES), Corner
of Shabnam Alley 119, Tehran, Iran; No 101, Ghaem Magham Farhani Street, Tehran, Iran; No. 11, Abshar Alley, Corner of Azodi Street, PO Box
15875-4155, Tehran 1581674347, Iran; Valfajr Blvd, Bushehr, Iran; Website www.valfajr.ir; Additional Sanctions Information - Subject to Secondary
Sanctions [IRAN].
VASEPARI SEPEHR PARS, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: GHADIR INVESTMENT
COMPANY).
WEST SUN TRADE GMBH (a.k.a. WEST SUN TRADE), Winterhuder Weg 8, Hamburg 22085, Germany; Arak Machine Mfg. Bldg., 2nd Floor, opp. of
College Economy, Northern Kargar Ave., Tehran 14136, Iran; Mundsburger Damm 16, Hamburg 22087, Germany; Additional Sanctions Information -
Subject to Secondary Sanctions; Registration ID HRB 45757 (Germany); all offices worldwide [IRAN].
WITSHIPPING MARITIME PTE LTD (a.k.a. HARDSEA AGENCIES; f.k.a. SINOSE MARITIME), Hoe Chiang Road 10, #15-02a, Central Business
District 089315, Singapore; Additional Sanctions Information - Subject to Secondary Sanctions; Trade License No. 201131193Z (Singapore) [IRAN].
WORLDFAST INTERNATIONAL LIMITED (a.k.a. WORLDFAST INTERNATIONAL LTD), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-
4833, Tehran, Iran; Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
WORLDWIDE SHIPPING & TRANSPORTATION LIMITED (a.k.a. WORLDWIDE SHIPPING & TRANS; a.k.a. WORLDWIDE SHIPPING AND TRANS;
a.k.a. WORLDWIDE SHIPPING AND TRANSPORTATION LIMITED), East Shahid Atefi Street 35, Africa Boulevard, PO Box 19395-4833, Tehran, Iran;
Additional Sanctions Information - Subject to Secondary Sanctions [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ZARIN PERSIA INVESTMENT, Iran [IRAN] (Linked To: GHADIR INVESTMENT COMPANY).
ZARIN RAFSANJAN CEMENT COMPANY (a.k.a. RAFSANJAN CEMENT COMPANY; a.k.a. ZARRIN RAFSANJAN CEMENT COMPANY), 2nd Floor,
No. 67, North Sindokht Street, West Dr. Fatemi Avenue, Tehran 1411953943, Iran; Website http://www.zarrincement.com; Additional Sanctions
Information - Subject to Secondary Sanctions [IRAN].
The following vessels have been added to OFAC's SDN List:
AAJ Crew/Supply Vessel Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 8984484
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 22/83
ABBA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9051624
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ABTIN 1 Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9379636
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ABYAN Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9349667
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ALVAN General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9165798
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
AMBER (f.k.a. FREEDOM; f.k.a. HARAZ) (5IM 597) Crude Oil Tanker 317,356DWT 163,660GRT Panama flag; Former Vessel Flag Cyprus; alt. Former
Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9357406; MMSI
677049700 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
AMINA Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9305192
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ANDIA Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9193197
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
APAMA (f.k.a. ABELIA; f.k.a. ASTARA; f.k.a. JUPITER) (9HDS9) Crude/Oil Products Tanker 99,087DWT 56,068GRT Iran flag; Former Vessel Flag
Tuvalu; alt. Former Vessel Flag Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9187631; MMSI 256845000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ARDAVAN Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9465863
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
AREZOO General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9165786
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARGO I (f.k.a. AMOL; a.k.a. ARGO 1; f.k.a. CASTOR; f.k.a. CHRISTINA; f.k.a. SILVER CLOUD) (T2EM4) Crude/Oil Products Tanker 99,094DWT
56,068GRT Panama flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions
Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9187667; MMSI 256843000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
ARIES Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9369722
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARK (f.k.a. ABADEH; f.k.a. CRYSTAL; f.k.a. SUNDIAL) (9HDQ9) Crude/Oil Products Tanker 99,030DWT 56,068GRT Panama flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9187655; MMSI 256842000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ARNICA (f.k.a. ALERT; f.k.a. ASTANEH; f.k.a. NEPTUNE; f.k.a. SEAPRIDE) (T2ES4) Crude/Oil Products Tanker 99,144DWT 56,068GRT Iran flag;
Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary
Sanctions; Vessel Registration Identification IMO 9187643; MMSI 572467210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ARSHAM Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9386500
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARTABAZ Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9283007
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARTAM Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9284154
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARTARIA Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9226944
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARTAVAND Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9193214
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARTAVIL (f.k.a. ABADAN; f.k.a. ALPHA; f.k.a. SHONA) (T2EU4) Crude/Oil Products Tanker 99,144DWT 56,068GRT Iran flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; alt. Former Vessel Flag Tanzania; Additional Sanctions Information -
Subject to Secondary Sanctions; Vessel Registration Identification IMO 9187629; MMSI 572469210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
ARTENOS Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9283021
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARTIN Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9305221 (vessel)
[IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 23/83
ARTMAN Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9405930
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARVIN Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9193202
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ARZIN Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9284142
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ATLANTIC (f.k.a. SEAGULL) Crude Oil Tanker Liberia flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 9107655 (vessel) [IRAN].
AURA (f.k.a. OCEAN PERFORMER) Crude Oil Tanker Mongolia flag; Former Vessel Flag Liberia; Additional Sanctions Information - Subject to
Secondary Sanctions; Vessel Registration Identification IMO 9013749 (vessel) [IRAN].
AVANG Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9465746
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
AYNAZ Tug Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9683570 (vessel) [IRAN]
(Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
AYSAN General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9165803
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
AZARGOUN Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9283019 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BADR (EQJU) Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 8407345 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BAHJAT Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9405954
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BANEH (EQKF) Landing Craft 640DWT 478GRT Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 8508462; MMSI 422141000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BASHT Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9346536
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BASKAR Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9405942
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BATIS Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9465760 (vessel)
[IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BAVAND Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9387798
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BEHDAD General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9051636
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BEHDOKHT Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9405978
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BEHNAVAZ Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9346548
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BEHSHAD General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9167289
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BEHTA Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9349590
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
BELEMA LIGHT CRUDE (f.k.a. MAHARLIKA; f.k.a. NOOR) (9HES9) Crude Oil Tanker 298,732DWT 156,809GRT Panama flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 9079066; MMSI 256882000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BICAS (f.k.a. GLAROS) Crude Oil Tanker Liberia flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 9077850 (vessel) [IRAN].
BRELYAN Passenger Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Other Vessel Type Roll-on Roll-off; Vessel
Registration Identification IMO 9138056 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 24/83
BRIGHT (f.k.a. ZAP) Crude Oil Tanker Mongolia flag; Former Vessel Flag Liberia; Additional Sanctions Information - Subject to Secondary Sanctions;
Vessel Registration Identification IMO 9005235 (vessel) [IRAN].
CANREACH (f.k.a. HAMOUN) Container Ship Hong Kong flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 9820271 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
CARIBO (f.k.a. NEREYDA) Crude Oil Tanker Panama flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 9011246 (vessel) [IRAN].
CASPIA Chemical/Products Tanker Panama flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification
IMO 9125126 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
DAN (f.k.a. JUSTICE) Crude Oil Tanker Panama flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 9357729 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DANIEL (f.k.a. DEMOS) (5IM656) Crude Oil Tanker Panama flag (NITC); Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to
Secondary Sanctions; Vessel Registration Identification IMO 9569683 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DARYABAR Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9369710
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
DEEP SEA (f.k.a. DARAB) (9HEE9) Crude Oil Tanker 296,803DWT 160,576GRT Panama flag; Former Vessel Flag Malta; Additional Sanctions
Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9218492; MMSI 256862000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
DELICE Chemical/Products Tanker Panama flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification
IMO 9125138 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
DELNAVAZ Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9387803
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
DELRUBA Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9305207
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
DERYA Crude Oil Tanker Panama flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9569700 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DESTINY (f.k.a. ULYSSES 1) Crude Oil Tanker Panama flag; Former Vessel Flag Liberia; alt. Former Vessel Flag Mongolia; Additional Sanctions
Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9177155 (vessel) [IRAN].
DEVON (f.k.a. DELVAR) (9HEF9) Crude Oil Tanker 299,500DWT 160,576GRT None Identified flag; Former Vessel Flag Malta; Additional Sanctions
Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9218454; MMSI 256864000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
DEVREZ Chemical/Products Tanker Panama flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification
IMO 9120994 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
DIAMOND II (f.k.a. DAMAVAND) (9HEG9) Crude Oil Tanker 297,013DWT 160,576GRT Panama flag; Former Vessel Flag Malta; Additional Sanctions
Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9218478; MMSI 256865000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
DINO I (f.k.a. INFINITY) (5IM411) Crude Oil Tanker Panama flag (NITC); Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to
Secondary Sanctions; Vessel Registration Identification IMO 9569671 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DIONA Crude Oil Tanker Panama flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9569695 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DORE (f.k.a. COMPANION; f.k.a. DAL LAKE; f.k.a. DAVAR) (5IM 593) Crude Oil Tanker 317,850DWT 164,241GRT Panama flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9357717; MMSI 677049300 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DORENA (f.k.a. SKYLINE) (5IM632) Crude Oil Tanker Panama flag (NITC); Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to
Secondary Sanctions; Vessel Registration Identification IMO 9569669 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DORITA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 8605234
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
DOVER (f.k.a. DAYLAM) (9HEU9) Crude Oil Tanker 299,500DWT 160,576GRT Panama flag; Former Vessel Flag Malta; Additional Sanctions
Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9218466; MMSI 256872000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 25/83
DOWNY (f.k.a. DENA) (9HED9) Crude Oil Tanker 296,894DWT 160,576GRT Panama flag; Former Vessel Flag Malta; Additional Sanctions Information -
Subject to Secondary Sanctions; Vessel Registration Identification IMO 9218480; MMSI 256861000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
DREAM II (f.k.a. DANESH; f.k.a. DECESIVE; f.k.a. LEADERSHIP) (5IM 592) Crude Oil Tanker 319,988DWT 164,241GRT Panama flag; Former Vessel
Flag Cyprus; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification
IMO 9356593; MMSI 677049200 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DUNE Crude Oil Tanker Panama flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9569712 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ELYANA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9165827
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
FANREACH (f.k.a. BARZIN) Container Ship Hong Kong flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 9820269 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
FAXON Chemical/Products Tanker Panama flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification
IMO 9283758 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
FELICITY (f.k.a. LEYCOTHEA; f.k.a. ORIENTAL) Crude Oil Tanker Panama flag; Former Vessel Flag Panama; Additional Sanctions Information -
Subject to Secondary Sanctions; Vessel Registration Identification IMO 9183934 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
FIROUZEH Passenger Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9103099
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
FOREST (f.k.a. FAEZ; f.k.a. FIANGA; f.k.a. MAESTRO; f.k.a. SATEEN) (T2DM4) Chemical/Products Tanker 35,124DWT 25,214GRT Panama flag;
Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary
Sanctions; Vessel Registration Identification IMO 9283760; MMSI 572438210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
FORTUNE (f.k.a. IRAN FAZEL) (9BAC) Chemical/Products Tanker 35,155DWT 25,214GRT Panama flag; Former Vessel Flag Iran; Additional Sanctions
Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9283746; MMSI 422303000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
GANJ Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9305219 (vessel)
[IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
GILDA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9367982
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
GOLAFRUZ Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9323833
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
GOLBON Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9283033
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
GOLSAN General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9165815
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
GOLSAR Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9193185
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
GOODREACH (f.k.a. RADIN) Container Ship Hong Kong flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 9820257 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
HALTI (f.k.a. HORIZON; f.k.a. HORMOZ; f.k.a. SCORPIAN) (9HEK9) Crude Oil Tanker 299,261DWT 160,930GRT Panama flag; Former Vessel Flag
Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9212890; MMSI 256870000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HAMD Bunkering Tanker Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9036052
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
HAMGAM Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9226956
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
HAPPINESS I (f.k.a. HAPPINESS; f.k.a. HENGAM; f.k.a. LOYAL; f.k.a. TULAR) (T2ER4) Crude Oil Tanker 299,214DWT 160,930GRT Panama flag;
Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary
Sanctions; Vessel Registration Identification IMO 9212905; MMSI 256875000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HASNA (f.k.a. HARSIN; f.k.a. MARINA; f.k.a. VALOR) (5IM600) Crude Oil Tanker 299,229DWT 160,930GRT Panama flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9212917;
MMSI 677050000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 26/83
HEDY (f.k.a. HUWAYZEH) (9HEJ9) Crude Oil Tanker 299,242DWT 160,930GRT Panama flag; Former Vessel Flag Malta; Additional Sanctions
Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9212888; MMSI 256869000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
HELM (f.k.a. HIRMAND; f.k.a. HONESTY; f.k.a. MILLIONAIRE) (T2DZ4) Crude Oil Tanker 317,356DWT 163,660GRT Panama flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 9357391; MMSI 572450210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HENNA (f.k.a. HALISTIC; f.k.a. HAMOON; f.k.a. LENA; f.k.a. TAMAR) (T2EQ4) Crude Oil Tanker 299,242DWT 160,930GRT Panama flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary
Sanctions; Vessel Registration Identification IMO 9212929; MMSI 572465210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HERBY (f.k.a. EXPLORER; f.k.a. HODA; f.k.a. HYDRA; f.k.a. PRECIOUS) (T2EH4) Crude Oil Tanker 317,356DWT 163,660GRT Panama flag; Former
Vessel Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary
Sanctions; Vessel Registration Identification IMO 9362059; MMSI 572458210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HERO II (f.k.a. HADI; f.k.a. PIONEER; f.k.a. ZEUS) (T2EJ4) Crude Oil Tanker 317,355DWT 163,650GRT Panama flag; Former Vessel Flag Cyprus; alt.
Former Vessel Flag Tuvalu; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9362073; MMSI
572459210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HILDA I (f.k.a. COURAGE; f.k.a. HOMA) (5IM 596) Crude Oil Tanker 317,367DWT 163,660GRT Panama flag; Former Vessel Flag Cyprus; alt. Former
Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9357389; MMSI
677049600 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HORMUZ 2 Passenger Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 7904580
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
HORSE (f.k.a. DOVE; f.k.a. HONAR; f.k.a. JANUS; f.k.a. VICTORY) (T2EA4) Crude Oil Tanker 317,367DWT 163,660GRT Panama flag; Former Vessel
Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions;
Vessel Registration Identification IMO 9362061; MMSI 209511000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HUGE (f.k.a. GLORY; f.k.a. HATEF; f.k.a. MAJESTIC) (T2EG4) Crude Oil Tanker 317,367DWT 163,660GRT Panama flag; Former Vessel Flag Cyprus;
alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 9357183; MMSI 212256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HUMANITY (f.k.a. OCEAN NYMPH) Crude Oil Tanker Panama flag; Former Vessel Flag Panama; alt. Former Vessel Flag Mongolia; Additional
Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9180281 (vessel) [IRAN].
HYUNDAI MIPO 2655 (a.k.a. YARD NO.2655 HYUNDAI M.D.) Products Tanker Iran flag; Additional Sanctions Information - Subject to Secondary
Sanctions; Vessel Registration Identification IMO 9820312 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
HYUNDAI MIPO 2656 (a.k.a. YARD NO.2656 HYUNDAI M.D.) Products Tanker Iran flag; Additional Sanctions Information - Subject to Secondary
Sanctions; Vessel Registration Identification IMO 9820324 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
HYUNDAI MIPO 2657 (a.k.a. YARD NO.2657 HYUNDAI M.D.) Tanker Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions;
Vessel Registration Identification IMO 9820336 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
IMICO NEKA 455 (a.k.a. YARD NO. 455 IRAN MARINE) Shuttle Tanker 63,000DWT 40,800GRT Iran flag; Additional Sanctions Information - Subject to
Secondary Sanctions; Vessel Registration Identification IMO 9404546 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
IMICO NEKA 456 (a.k.a. YARD NO. 456 IRAN MARINE) Shuttle Tanker 63,000DWT 40,800GRT Iran flag; Additional Sanctions Information - Subject to
Secondary Sanctions; Vessel Registration Identification IMO 9404558 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
IMICO NEKA 457 (a.k.a. YARD NO. 457 IRAN MARINE) Shuttle Tanker 63,000DWT 40,800GRT Iran flag; Additional Sanctions Information - Subject to
Secondary Sanctions; Vessel Registration Identification IMO 9404560 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
IRAN CHARAK Bunkering Tanker Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
8322076 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
IRAN FAHIM Chemical/Products Tanker 34,900DWT 26,561GRT Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 9286140 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
IRAN FALAGH Chemical/Products Tanker 34,900DWT 25,000GRT Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 9286152 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
IRAN HORMUZ 12 (a.k.a. IRAN HORMOZ 12) Passenger Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Other Vessel
Type Roll-on Roll-off; Vessel Registration Identification IMO 9005596 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
IRAN HORMUZ 14 (a.k.a. IRAN HORMOZ 14) Passenger Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Other Vessel
Type Roll-on Roll-off; Vessel Registration Identification IMO 9020778 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 27/83
IRAN HORMUZ 22 Passenger Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Other Vessel Type Landing Craft; Vessel
Registration Identification IMO 8314275 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
IRAN HORMUZ 25 (a.k.a. HAYAN) Roll-on Roll-off Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Other Vessel Type
General Cargo; Vessel Registration Identification IMO 8422072 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
IRAN PARAK Bunkering Tanker Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
8322064 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
IRAN SHAHED General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9184691 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
IRAN SHALAK Bunkering Tanker Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
8319940 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
IRAN SHALAMCHEH (a.k.a. IR.SHALAMCHE; a.k.a. SEPEHR SAM) General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary
Sanctions; Vessel Registration Identification IMO 8820925 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
IRAN YOUSHAT Bunkering Tanker Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
8319952 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
JAIRAN General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9167291
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
KADOS General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9137258
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
KASHAN Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9270696
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
KASMA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 8721351
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
KHURAN Products Tanker Togo flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9032666
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
KIAZAND Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9465758
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
MAHNAM Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9213387
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
MARIA III (f.k.a. SUNRISE) LPG Tanker Panama flag (NITC); Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 9615092 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MARIVAN (EQKH) Bunkering Tanker 640DWT 478GRT Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 8517243; MMSI 422143000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MENA Crude/Oil Products Tanker Togo flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
8909472 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
MIAMI PRIDE Bulk Carrier Togo flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9274941
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
NAINITAL (f.k.a. MIDSEA; f.k.a. MOTION; f.k.a. NAJM) (T2DR4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 9079092; MMSI 572442210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NARDIS General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9137246
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
NASHA (f.k.a. NATIVE LAND; f.k.a. NESA; f.k.a. OCEANIC; f.k.a. TRUTH) (T2DP4) Crude Oil Tanker 298,732DWT 156,809GRT Panama flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary
Sanctions; Vessel Registration Identification IMO 9079107; MMSI 572440210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NAVARZ (f.k.a. ELITE; f.k.a. NAPOLI; f.k.a. NOAH; f.k.a. VOYAGER) (T2DQ4) Crude Oil Tanker 298,731DWT 156,809GRT Panama flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions;
Vessel Registration Identification IMO 9079078; MMSI 572441210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NEGAR General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9165839
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 28/83
NEGEEN Passenger Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9071519
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
NESHAT General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9167277
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
NOOR 1 Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9506320
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
NYOS (f.k.a. BRAWNY; f.k.a. MARIGOLD; f.k.a. NABI) (T2DS4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 9079080; MMSI 572443210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
OURA Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9387815 (vessel)
[IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
PARAND General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9118551
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
PARIN General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9076478
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
PARISAN Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9465851
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
PARMIS General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9245316
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
PARNIA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9167265
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
PARSHAD Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9387786
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
PARSHAN General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9051648
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
PATRIS General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9137210
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
PERARIN Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9209350
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ROSHAK Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9405966
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SABITI (f.k.a. LANTANA; f.k.a. SANANDAJ; f.k.a. SPOTLESS) (5IM591) Crude Oil Tanker 159,681DWT 81,479GRT Panama flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9172040; MMSI 677049100 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SABRINA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 8215742
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SALINA (f.k.a. BLACKSTONE; f.k.a. SARV; f.k.a. SPLENDOUR) (9HNZ9) Crude Oil Tanker 163,870DWT 85,462GRT Panama flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Seychelles; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 9357377; MMSI 249257000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SANA (f.k.a. BAIKAL; f.k.a. BLOSSOM; f.k.a. SIMA; f.k.a. SUCCESS) (T2DY4) Crude Oil Tanker 164,154DWT 85,462GRT Panama flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions;
Vessel Registration Identification IMO 9357353; MMSI 572449210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SANCHI (f.k.a. GARDENIA; f.k.a. SEAHORSE; f.k.a. SEPID) (T2EF4) Crude Oil Tanker 164,154DWT 85,462GRT None Identified flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions;
Vessel Registration Identification IMO 9356608; MMSI 572455210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SANIA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9367994
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SARDASHT (EQKG) Landing Craft 640DWT 478GRT Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 8517231; MMSI 422142000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SARINA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 8203608
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 29/83
SARIR General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9368003
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SARVIN Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9209348
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SAVIZ General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9167253
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SEA CLIFF (f.k.a. SMOOTH; a.k.a. YARD NO. 1225 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT Panama flag; Former
Vessel Flag Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9569657 (vessel) [IRAN]
(Linked To: NATIONAL IRANIAN TANKER COMPANY).
SEA STAR III (f.k.a. CARNATION; f.k.a. SAFE; a.k.a. SEASTAR III; f.k.a. SUNSHINE; a.k.a. YARD NO. 1220 SHANGHAI WAIGAOQIAO) Crude Oil
Tanker 318,000DWT 165,000GRT Panama flag; Former Vessel Flag Tuvalu; alt. Former Vessel Flag Malta; alt. Former Vessel Flag Tanzania;
Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9569205 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
SERENA (f.k.a. SALALEH; f.k.a. SONGBIRD; a.k.a. YARD NO. 1224 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT Panama
flag; Former Vessel Flag Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9569645
(vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SHABDIS Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9349588
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SHABGOUN Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9346524 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SHAHR E KORD Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9270684 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SHAHRAZ Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9349576
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SHAMIM Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9270658
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SHAYAN 1 Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9420356
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SHIBA Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9270646
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SILVIA I (f.k.a. MAGNOLIA; f.k.a. SABRINA; f.k.a. SARVESTAN) (5IM590) Crude Oil Tanker 159,711DWT 81,479GRT Panama flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9172052; MMSI 677049000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SINOPA (f.k.a. DAISY; f.k.a. SUPERIOR; f.k.a. SUSANGIRD) (5IM584) Crude Oil Tanker 159,681DWT 81,479GRT Panama flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9172038; MMSI 677048400 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SNOW (f.k.a. DOJRAN; f.k.a. RAINBOW; f.k.a. SOUVENIR; a.k.a. YARD NO. 1221 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT
165,000GRT Panama flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions
Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9569619 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
SOBHAN Bunkering Tanker Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9036935
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SOL (f.k.a. CAMELLIA; f.k.a. SAVEH; f.k.a. SWALLOW) (5IM 594) Crude Oil Tanker 159,758DWT 81,479GRT Panama flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9171462;
MMSI 677049400 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SOMIA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9368015
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
SONIA I (f.k.a. AZALEA; f.k.a. SINA; f.k.a. SUNEAST) (9HNY9) Crude Oil Tanker 164,154DWT 85,462GRT Panama flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; alt. Former Vessel Flag Seychelles; Additional Sanctions Information - Subject to
Secondary Sanctions; Vessel Registration Identification IMO 9357365; MMSI 249256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 30/83
STARK I (f.k.a. CLOVE; f.k.a. SEMNAN; f.k.a. SPARROW) (5IM 595) Crude Oil Tanker 159,681DWT 81,479GRT Panama flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
9171450; MMSI 677049500 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
STARLA (f.k.a. ATLANTIS) (5IM316) Crude Oil Tanker Panama flag (NITC); Former Vessel Flag Tanzania; Additional Sanctions Information - Subject to
Secondary Sanctions; Vessel Registration Identification IMO 9569621 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
STREAM (f.k.a. FORTUN; f.k.a. SONATA; a.k.a. YARD NO. 1222 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT Panama
flag; Former Vessel Flag Malta; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9569633
(vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
TABAN 1 Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9420368
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
TABUK Crude/Oil Products Tanker Togo flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO
8917467 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
TARADIS General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9245304
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
TENREACH (f.k.a. RAYEN) Container Ship Hong Kong flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 9820245 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
TERMEH Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9213399
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
TOLOU (EQOD) Crew/Supply Vessel 250DWT 178GRT Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 8318178 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
TOUSKA Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9328900
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
VALFAJR2 (EQOX) Tug 650DWT 419GRT Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration
Identification IMO 8400103 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
VIANA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9010723
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
VISTA General Cargo Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9010711
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
WARTA Bulk Carrier Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9465849
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
YAGHOUB (EQOE) Platform Supply Ship 950DWT 1,019GRT Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 8316168; MMSI 422150000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YANGZHOU DAYANG DY905 (a.k.a. YARD NO. DY905 YANGZHOU D.) LPG Tanker 11,750DWT 8,750GRT Iran flag; Additional Sanctions Information
- Subject to Secondary Sanctions; Vessel Registration Identification IMO 9575424 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER
COMPANY).
YARAN Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9420370
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
YOUNES (EQYY) Platform Supply Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification
IMO 8212465 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YOUSEF (EQOG) Offshore Tug/Supply Ship 1,050DWT 584GRT Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel
Registration Identification IMO 8316106; MMSI 422144000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ZARDIS Container Ship Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Vessel Registration Identification IMO 9349679
(vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
ZOMOROUD Passenger Iran flag; Additional Sanctions Information - Subject to Secondary Sanctions; Other Vessel Type Roll-on Roll-off; Vessel
Registration Identification IMO 9138044 (vessel) [IRAN] (Linked To: ISLAMIC REPUBLIC OF IRAN SHIPPING LINES).
The following aircraft have been added to OFAC's SDN List:
EP-CFD; Aircraft Manufacture Date 19 Feb 1993; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11442;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFE; Aircraft Manufacture Date 06 Oct 1992; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11422;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 31/83
EP-CFH; Aircraft Manufacture Date 24 Feb 1993; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11443;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFI; Aircraft Manufacture Date 22 Jan 1996; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11511;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFJ; Aircraft Manufacture Date 09 Jan 1996; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11516;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFK; Aircraft Manufacture Date 18 Feb 1996; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11518;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFL; Aircraft Manufacture Date 28 Jun 1991; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11343;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFM; Aircraft Manufacture Date 27 Apr 1992; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11394;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFO; Aircraft Manufacture Date 03 Apr 1992; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11389;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFP; Aircraft Manufacture Date 24 Jul 1992; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11409;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFQ; Aircraft Manufacture Date 02 Dec 1992; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11429;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-CFR; Aircraft Manufacture Date 31 Mar 1992; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11383;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IAB; Aircraft Manufacture Date 22 Apr 1976; Aircraft Model B747; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 20999;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IAC; Aircraft Manufacture Date 16 May 1977; Aircraft Model B747; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 21093;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IAD; Aircraft Manufacture Date 26 Apr 1979; Aircraft Model B747; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 21758;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IAG; Aircraft Manufacture Date 21 Jul 1976; Aircraft Model B747; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 21217;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IAH; Aircraft Manufacture Date 22 Dec 1976; Aircraft Model B747; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 21218;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IAI; Aircraft Manufacture Date 01 Dec 1981; Aircraft Model B747; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 22670;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBA; Aircraft Manufacture Date 21 Dec 1993; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 723;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBB; Aircraft Manufacture Date 18 Jan 1994; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 727;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBC; Aircraft Manufacture Date 11 Mar 1992; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 632;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBD; Aircraft Manufacture Date Apr 1993; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 696;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBG; Aircraft Manufacture Date 09 Aug 1984; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 299;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBI; Aircraft Manufacture Date 09 Jun 1981; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 151;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBJ; Aircraft Manufacture Date 18 May 1983; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 256;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBK; Aircraft Manufacture Date 19 Feb 1993; Aircraft Model A310; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 671;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 32/83
EP-IBL; Aircraft Manufacture Date 02 May 1987; Aircraft Model A310; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 436;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBN; Aircraft Manufacture Date 16 Apr 1985; Aircraft Model A310; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 375;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBP; Aircraft Manufacture Date 06 Jan 1986; Aircraft Model A310; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 370;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBQ; Aircraft Manufacture Date 20 Jan 1986; Aircraft Model A310; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 389;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBS; Aircraft Manufacture Date 13 Feb 1980; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 80;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBT; Aircraft Manufacture Date 09 Mar 1982; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 185;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IBZ; Aircraft Manufacture Date 13 Dec 1982; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 226;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ICD; Aircraft Manufacture Date 15 Sep 1988; Aircraft Model B747; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 24134;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ICE; Aircraft Manufacture Date 11 Mar 1981; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 139;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ICF; Aircraft Manufacture Date 14 Dec 1981; Aircraft Model A300; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 173;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IDA; Aircraft Manufacture Date 12 Jun 1990; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11292;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IDD; Aircraft Manufacture Date 31 Oct 1990; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11294;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IDF; Aircraft Manufacture Date 07 Nov 1990; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11298;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IDG; Aircraft Manufacture Date 30 Jan 1991; Aircraft Model F28; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 11302;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IEB; Aircraft Manufacture Date 26 Jan 1996; Aircraft Model A320; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 575;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IEC; Aircraft Manufacture Date 18 Jun 1998; Aircraft Model A320; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 857;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IED; Aircraft Manufacture Date 18 Jun 1992; Aircraft Model A320; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 345;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IEE; Aircraft Manufacture Date 14 Feb 1992; Aircraft Model A320; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 303;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IEF; Aircraft Manufacture Date 05 Mar 1992; Aircraft Model A320; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 312;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IEG; Aircraft Manufacture Date 06 Jun 2003; Aircraft Model A320; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 2054;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IFA; Aircraft Manufacture Date 16 Nov 2016; Aircraft Model A321; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 7418;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IJA; Aircraft Manufacture Date 02 Jun 2014; Aircraft Model A330; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1540;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IJB; Aircraft Manufacture Date 05 Nov 2014; Aircraft Model A330; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1586;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IRR; Aircraft Manufacture Date 24 Jun 1974; Aircraft Model B727; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 20946;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 33/83
EP-IRS; Aircraft Manufacture Date 12 Sep 1974; Aircraft Model B727; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 20947;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-IRT; Aircraft Manufacture Date 03 Mar 1975; Aircraft Model B727; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 21078;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITA; Aircraft Manufacture Date 05 Jan 2017; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1386;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITB; Aircraft Manufacture Date 17 Jan 2017; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1389;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITC; Aircraft Manufacture Date 11 Jan 2017; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1390;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITD; Aircraft Manufacture Date 28 Dec 2016; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1391;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITE; Aircraft Manufacture Date 27 Jul 2017; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1424;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITF; Aircraft Manufacture Date 04 Sep 2017; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1431;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITG; Aircraft Manufacture Date 20 Dec 2017; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1477;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITH; Aircraft Manufacture Date 11 Dec 2017; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1478;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITI; Aircraft Manufacture Date 22 Mar 2018; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1489;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITJ; Aircraft Manufacture Date 06 Apr 2018; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1494;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITK; Aircraft Manufacture Date 19 Jun 2018; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1503;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITL; Aircraft Manufacture Date 24 May 2018; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1504;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
EP-ITM; Aircraft Manufacture Date 03 Jul 2018; Aircraft Model ATR-72; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 1510;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
UR-BXI; Aircraft Manufacture Date Jun 1993; Aircraft Model DC-9; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 53170;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
UR-CBD; Aircraft Manufacture Date Mar 1989; Aircraft Model DC-9; Aircraft Operator Iran Air; Aircraft Manufacturer's Serial Number (MSN) 49510;
Additional Sanctions Information - Subject to Secondary Sanctions (aircraft) [IRAN] (Linked To: IRAN AIR).
The following changes have been made to OFAC's SDN List:
TIDEWATER MIDDLE EAST CO. (a.k.a. FARAZ ROYAL QESHM LLC; a.k.a. TIDE WATER COMPANY; a.k.a. TIDE WATER MIDDLE EAST MARINE
SERVICE; a.k.a. TIDEWATER CO. (MIDDLE EAST MARINE SERVICES)), No. 80, Tidewater Building, Vozara Street, Next to Saie Park, Tehran, Iran;
Website www.tidewaterco.com; Email Address [email protected]; alt. Email Address [email protected]; IFCA Determination - Port Operator;
Additional Sanctions Information - Subject to Secondary Sanctions; Business Registration Document # 18745 (Iran); Telephone: 982188553321; Alt.
Telephone: 982188554432; Fax: 982188717367; Alt. Fax: 982188708761; Alt. Fax: 982188708911 [SDGT] [NPWMD] [IRGC] [IFSR]. -to- TIDEWATER
MIDDLE EAST CO. (a.k.a. FARAZ ROYAL QESHM LLC; a.k.a. TIDE WATER COMPANY; a.k.a. TIDE WATER MIDDLE EAST MARINE SERVICE;
a.k.a. TIDEWATER CO. (MIDDLE EAST MARINE SERVICES)), No. 80, Tidewater Building, Vozara Street, Next to Saie Park, Tehran, Iran; Website
www.tidewaterco.com; Email Address [email protected]; alt. Email Address [email protected]; IFCA Determination - Port Operator; Additional
Sanctions Information - Subject to Secondary Sanctions; Business Registration Document # 18745 (Iran); Telephone: 982188553321; Alt. Telephone:
982188554432; Fax: 982188717367; Alt. Fax: 982188708761; Alt. Fax: 982188708911 [SDGT] [NPWMD] [IRGC] [IFSR] [IFCA].
The following deletions have been made to OFAC's Executive Order 13599 List:
BANK MARKAZI JOMHOURI ISLAMI IRAN (a.k.a. BANK MARKAZI IRAN; a.k.a. CENTRAL BANK OF IRAN; a.k.a. CENTRAL BANK OF THE
ISLAMIC REPUBLIC OF IRAN), PO Box 15875/7177, 144 Mirdamad Blvd, Tehran, Iran; 213 Ferdowsi Avenue, Tehran 11365, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 34/83
CENTRAL BANK OF THE ISLAMIC REPUBLIC OF IRAN (a.k.a. BANK MARKAZI IRAN; a.k.a. BANK MARKAZI JOMHOURI ISLAMI IRAN; a.k.a.
CENTRAL BANK OF IRAN), PO Box 15875/7177, 144 Mirdamad Blvd, Tehran, Iran; 213 Ferdowsi Avenue, Tehran 11365, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BANK MARKAZI IRAN (a.k.a. BANK MARKAZI JOMHOURI ISLAMI IRAN; a.k.a. CENTRAL BANK OF IRAN; a.k.a. CENTRAL BANK OF THE
ISLAMIC REPUBLIC OF IRAN), PO Box 15875/7177, 144 Mirdamad Blvd, Tehran, Iran; 213 Ferdowsi Avenue, Tehran 11365, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
CENTRAL BANK OF IRAN (a.k.a. BANK MARKAZI IRAN; a.k.a. BANK MARKAZI JOMHOURI ISLAMI IRAN; a.k.a. CENTRAL BANK OF THE
ISLAMIC REPUBLIC OF IRAN), PO Box 15875/7177, 144 Mirdamad Blvd, Tehran, Iran; 213 Ferdowsi Avenue, Tehran 11365, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BANK MASKAN (a.k.a. HOUSING BANK (OF IRAN)), PO Box 11365/5699, No 247 3rd Floor Fedowsi Ave, Cross Sarhang Sakhaei St, Tehran, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
HOUSING BANK (OF IRAN) (a.k.a. BANK MASKAN), PO Box 11365/5699, No 247 3rd Floor Fedowsi Ave, Cross Sarhang Sakhaei St, Tehran, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
BANK REFAH KARGARAN (a.k.a. BANK REFAH; a.k.a. WORKERS' WELFARE BANK (OF IRAN)), No. 40 North Shiraz Street, Mollasadra Ave, Vanak
Sq, Tehran 19917, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
WORKERS' WELFARE BANK (OF IRAN) (a.k.a. BANK REFAH; a.k.a. BANK REFAH KARGARAN), No. 40 North Shiraz Street, Mollasadra Ave, Vanak
Sq, Tehran 19917, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
BANK REFAH (a.k.a. BANK REFAH KARGARAN; a.k.a. WORKERS' WELFARE BANK (OF IRAN)), No. 40 North Shiraz Street, Mollasadra Ave, Vanak
Sq, Tehran 19917, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
BANK OF INDUSTRY AND MINE (OF IRAN) (a.k.a. BANK SANAD VA MADAN; a.k.a. "BIM"), PO Box 15875-4456, Firouzeh Tower, No 1655 Vali-Asr
Ave after Chamran Crossroads, Tehran 1965643511, Iran; No 1655, Firouzeh Building, Mahmoudiye Street, Valiasr Ave, Tehran, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
BANK SANAD VA MADAN (a.k.a. BANK OF INDUSTRY AND MINE (OF IRAN); a.k.a. "BIM"), PO Box 15875-4456, Firouzeh Tower, No 1655 Vali-Asr
Ave after Chamran Crossroads, Tehran 1965643511, Iran; No 1655, Firouzeh Building, Mahmoudiye Street, Valiasr Ave, Tehran, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
"BIM" (a.k.a. BANK OF INDUSTRY AND MINE (OF IRAN); a.k.a. BANK SANAD VA MADAN), PO Box 15875-4456, Firouzeh Tower, No 1655 Vali-Asr
Ave after Chamran Crossroads, Tehran 1965643511, Iran; No 1655, Firouzeh Building, Mahmoudiye Street, Valiasr Ave, Tehran, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
BANK KESHAVARZI IRAN (a.k.a. AGRICULTURAL BANK OF IRAN; a.k.a. BANK KESHAVARZI), PO Box 14155-6395, 129 Patrice Lumumba St,
Jalal-al-Ahmad Expressway, Tehran 14454, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
AGRICULTURAL BANK OF IRAN (a.k.a. BANK KESHAVARZI; a.k.a. BANK KESHAVARZI IRAN), PO Box 14155-6395, 129 Patrice Lumumba St,
Jalal-al-Ahmad Expressway, Tehran 14454, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
BANK KESHAVARZI (a.k.a. AGRICULTURAL BANK OF IRAN; a.k.a. BANK KESHAVARZI IRAN), PO Box 14155-6395, 129 Patrice Lumumba St,
Jalal-al-Ahmad Expressway, Tehran 14454, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 35/83
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
BANK TEJARAT, PO Box 11365-5416, 152 Taleghani Avenue, Tehran 15994, Iran; 130, Zandi Alley, Taleghani Avenue, No 152, Ostad Nejat Ollahi
Cross, Tehran 14567, Iran; 124-126 Rue de Provence, Angle 76 bd Haussman, Paris 75008, France; PO Box 734001, Rudaki Ave 88, Dushanbe
734001, Tajikistan; Office C208, Beijing Lufthansa Center No 50, Liangmaqiao Rd, Chaoyang District, Beijing 100016, China; c/o Europaisch-Iranische
Handelsbank AG, Depenau 2, D-20095, Hamburg, Germany; SWIFT/BIC BTEJIRTH; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices
worldwide [IRAN].
EUROPAISCH-IRANISCHE HANDELSBANK AG (f.k.a. DEUTSCH-IRANISCHE HANDELSBANK AG; a.k.a. EUROPAEISCH-IRANISCHE
HANDELSBANK; a.k.a. EUROPAESCH-IRANISCHE HANDELSBANK AKTIENGESELLSCHAFT; a.k.a. GERMAN-IRANIAN TRADE BANK), Hamburg
Head Office, Depenau 2, D-20095 Hamburg, P.O. Box 101304, D-20008 Hamburg, Hamburg , Germany; Kish Branch, Sanaee Avenue, PO Box
79415/148, Kish Island 79415, Iran; Tehran Branch, No. 1655/1, Valiasr Avenue, PO Box 19656 43 511, Tehran, Iran; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
DEUTSCH-IRANISCHE HANDELSBANK AG (a.k.a. EUROPAEISCH-IRANISCHE HANDELSBANK; a.k.a. EUROPAESCH-IRANISCHE
HANDELSBANK AKTIENGESELLSCHAFT; a.k.a. EUROPAISCH-IRANISCHE HANDELSBANK AG; a.k.a. GERMAN-IRANIAN TRADE BANK),
Hamburg Head Office, Depenau 2, D-20095 Hamburg, P.O. Box 101304, D-20008 Hamburg, Hamburg , Germany; Kish Branch, Sanaee Avenue, PO
Box 79415/148, Kish Island 79415, Iran; Tehran Branch, No. 1655/1, Valiasr Avenue, PO Box 19656 43 511, Tehran, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
EUROPAESCH-IRANISCHE HANDELSBANK AKTIENGESELLSCHAFT (f.k.a. DEUTSCH-IRANISCHE HANDELSBANK AG; a.k.a. EUROPAEISCHIRANISCHE
HANDELSBANK; a.k.a. EUROPAISCH-IRANISCHE HANDELSBANK AG; a.k.a. GERMAN-IRANIAN TRADE BANK), Hamburg Head
Office, Depenau 2, D-20095 Hamburg, P.O. Box 101304, D-20008 Hamburg, Hamburg , Germany; Kish Branch, Sanaee Avenue, PO Box 79415/148,
Kish Island 79415, Iran; Tehran Branch, No. 1655/1, Valiasr Avenue, PO Box 19656 43 511, Tehran, Iran; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
EUROPAEISCH-IRANISCHE HANDELSBANK (f.k.a. DEUTSCH-IRANISCHE HANDELSBANK AG; a.k.a. EUROPAESCH-IRANISCHE
HANDELSBANK AKTIENGESELLSCHAFT; a.k.a. EUROPAISCH-IRANISCHE HANDELSBANK AG; a.k.a. GERMAN-IRANIAN TRADE BANK),
Hamburg Head Office, Depenau 2, D-20095 Hamburg, P.O. Box 101304, D-20008 Hamburg, Hamburg , Germany; Kish Branch, Sanaee Avenue, PO
Box 79415/148, Kish Island 79415, Iran; Tehran Branch, No. 1655/1, Valiasr Avenue, PO Box 19656 43 511, Tehran, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
GERMAN-IRANIAN TRADE BANK (f.k.a. DEUTSCH-IRANISCHE HANDELSBANK AG; a.k.a. EUROPAEISCH-IRANISCHE HANDELSBANK; a.k.a.
EUROPAESCH-IRANISCHE HANDELSBANK AKTIENGESELLSCHAFT; a.k.a. EUROPAISCH-IRANISCHE HANDELSBANK AG), Hamburg Head
Office, Depenau 2, D-20095 Hamburg, P.O. Box 101304, D-20008 Hamburg, Hamburg , Germany; Kish Branch, Sanaee Avenue, PO Box 79415/148,
Kish Island 79415, Iran; Tehran Branch, No. 1655/1, Valiasr Avenue, PO Box 19656 43 511, Tehran, Iran; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
BANK SEPAH, Imam Khomeini Square, Tehran 1136953412, Iran; 64 Rue de Miromesnil, Paris 75008, France; Hafenstrasse 54, D-60327, Frankfurt
am Main, Germany; Via Barberini 50, Rome, RM 00187, Italy; 17 Place Vendome, Paris 75008, France; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
BANK MELLI IRAN (a.k.a. BANK MELLI; a.k.a. NATIONAL BANK OF IRAN), PO Box 11365-171, Ferdowsi Avenue, Tehran, Iran; 43 Avenue
Montaigne, Paris 75008, France; Room 704-6, Wheelock Hse, 20 Pedder St, Central, Hong Kong; Bank Melli Iran Bldg, 111 St 24, 929 Arasat,
Baghdad, Iraq; PO Box 2643, Ruwi, Muscat 112, Oman; PO Box 2656, Liva Street, Abu Dhabi, United Arab Emirates; PO Box 248, Hamad Bin
Abdulla St, Fujairah, United Arab Emirates; PO Box 1888, Clock Tower, Industrial Rd, Al Ain Club Bldg, Al Ain, Abu Dhabi, United Arab Emirates; PO
Box 1894, Baniyas St, Deira, Dubai City, United Arab Emirates; PO Box 5270, Oman Street Al Nakheel, Ras Al-Khaimah, United Arab Emirates; PO
Box 459, Al Borj St, Sharjah, United Arab Emirates; PO Box 3093, Ahmed Seddiqui Bldg, Khalid Bin El-Walid St, Bur-Dubai, Dubai City 3093, United
Arab Emirates; PO Box 1894, Al Wasl Rd, Jumeirah, Dubai, United Arab Emirates; Postfach 112 129, Holzbruecke 2, D-20459, Hamburg, Germany;
Nobel Ave. 14, Baku, Azerbaijan; Unit 1703-4, 17th Floor, Hong Kong Club Building, 3 A Chater Road Central, Hong Kong; Esteghlal St., Opposite to
Otbeh Ibn Ghazvan Hall , Basrah, Iraq; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
BANK MELLI (a.k.a. BANK MELLI IRAN; a.k.a. NATIONAL BANK OF IRAN), PO Box 11365-171, Ferdowsi Avenue, Tehran, Iran; 43 Avenue
Montaigne, Paris 75008, France; Room 704-6, Wheelock Hse, 20 Pedder St, Central, Hong Kong; Bank Melli Iran Bldg, 111 St 24, 929 Arasat,
Baghdad, Iraq; PO Box 2643, Ruwi, Muscat 112, Oman; PO Box 2656, Liva Street, Abu Dhabi, United Arab Emirates; PO Box 248, Hamad Bin
Abdulla St, Fujairah, United Arab Emirates; PO Box 1888, Clock Tower, Industrial Rd, Al Ain Club Bldg, Al Ain, Abu Dhabi, United Arab Emirates; PO
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 36/83
Box 1894, Baniyas St, Deira, Dubai City, United Arab Emirates; PO Box 5270, Oman Street Al Nakheel, Ras Al-Khaimah, United Arab Emirates; PO
Box 459, Al Borj St, Sharjah, United Arab Emirates; PO Box 3093, Ahmed Seddiqui Bldg, Khalid Bin El-Walid St, Bur-Dubai, Dubai City 3093, United
Arab Emirates; PO Box 1894, Al Wasl Rd, Jumeirah, Dubai, United Arab Emirates; Postfach 112 129, Holzbruecke 2, D-20459, Hamburg, Germany;
Nobel Ave. 14, Baku, Azerbaijan; Unit 1703-4, 17th Floor, Hong Kong Club Building, 3 A Chater Road Central, Hong Kong; Esteghlal St., Opposite to
Otbeh Ibn Ghazvan Hall , Basrah, Iraq; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
NATIONAL BANK OF IRAN (a.k.a. BANK MELLI; a.k.a. BANK MELLI IRAN), PO Box 11365-171, Ferdowsi Avenue, Tehran, Iran; 43 Avenue
Montaigne, Paris 75008, France; Room 704-6, Wheelock Hse, 20 Pedder St, Central, Hong Kong; Bank Melli Iran Bldg, 111 St 24, 929 Arasat,
Baghdad, Iraq; PO Box 2643, Ruwi, Muscat 112, Oman; PO Box 2656, Liva Street, Abu Dhabi, United Arab Emirates; PO Box 248, Hamad Bin
Abdulla St, Fujairah, United Arab Emirates; PO Box 1888, Clock Tower, Industrial Rd, Al Ain Club Bldg, Al Ain, Abu Dhabi, United Arab Emirates; PO
Box 1894, Baniyas St, Deira, Dubai City, United Arab Emirates; PO Box 5270, Oman Street Al Nakheel, Ras Al-Khaimah, United Arab Emirates; PO
Box 459, Al Borj St, Sharjah, United Arab Emirates; PO Box 3093, Ahmed Seddiqui Bldg, Khalid Bin El-Walid St, Bur-Dubai, Dubai City 3093, United
Arab Emirates; PO Box 1894, Al Wasl Rd, Jumeirah, Dubai, United Arab Emirates; Postfach 112 129, Holzbruecke 2, D-20459, Hamburg, Germany;
Nobel Ave. 14, Baku, Azerbaijan; Unit 1703-4, 17th Floor, Hong Kong Club Building, 3 A Chater Road Central, Hong Kong; Esteghlal St., Opposite to
Otbeh Ibn Ghazvan Hall , Basrah, Iraq; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
FUTURE BANK B.S.C. (a.k.a. BANK-E AL-MOSTAGHBAL; a.k.a. FUTURE BANK), P.O. Box 785, City Centre Building, Government Avenue, Manama,
Bahrain; Block 304, City Centre Building, Building 199, Government Avenue, Road 383, Manama, Bahrain; Free Trade Zone, Sanaati-e Kish, Vilay-e
Ferdos 2, Corner of Klinik-e Khanevadeh, No 1/5 and 3/5, Kish, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Business Registration
Document # 54514-1 (Bahrain) expires 09 Jun 2009; Trade License No. 13388 (Bahrain); All branches worldwide [IRAN].
BANK-E AL-MOSTAGHBAL (a.k.a. FUTURE BANK; a.k.a. FUTURE BANK B.S.C.), P.O. Box 785, City Centre Building, Government Avenue, Manama,
Bahrain; Block 304, City Centre Building, Building 199, Government Avenue, Road 383, Manama, Bahrain; Free Trade Zone, Sanaati-e Kish, Vilay-e
Ferdos 2, Corner of Klinik-e Khanevadeh, No 1/5 and 3/5, Kish, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Business Registration
Document # 54514-1 (Bahrain) expires 09 Jun 2009; Trade License No. 13388 (Bahrain); All branches worldwide [IRAN].
FUTURE BANK (a.k.a. BANK-E AL-MOSTAGHBAL; a.k.a. FUTURE BANK B.S.C.), P.O. Box 785, City Centre Building, Government Avenue, Manama,
Bahrain; Block 304, City Centre Building, Building 199, Government Avenue, Road 383, Manama, Bahrain; Free Trade Zone, Sanaati-e Kish, Vilay-e
Ferdos 2, Corner of Klinik-e Khanevadeh, No 1/5 and 3/5, Kish, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Business Registration
Document # 54514-1 (Bahrain) expires 09 Jun 2009; Trade License No. 13388 (Bahrain); All branches worldwide [IRAN].
EXPORT DEVELOPMENT BANK OF IRAN (a.k.a. BANK TOSEH SADERAT IRAN; a.k.a. BANK TOWSEEH SADERAT IRAN; a.k.a. BANK TOWSEH
SADERAT IRAN; a.k.a. EDBI), Tose'e Tower, Corner of 15th St., Ahmed Qasir Ave., Argentine Square, Tehran, Iran; No. 129, 21's Khaled Eslamboli,
No. 1 Building, Tehran, Iran; Export Development Building, Next to the 15th Alley, Bokharest Street, Argentina Square, Tehran, Iran; No. 26, Tosee
Tower, Arzhantine Square, P.O. Box 15875-5964, Tehran 15139, Iran; No. 4, Gandi Ave., Tehran 1516747913, Iran; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 86936 (Iran) issued 10 Jul 1991; all offices worldwide [IRAN].
EDBI (a.k.a. BANK TOSEH SADERAT IRAN; a.k.a. BANK TOWSEEH SADERAT IRAN; a.k.a. BANK TOWSEH SADERAT IRAN; a.k.a. EXPORT
DEVELOPMENT BANK OF IRAN), Tose'e Tower, Corner of 15th St., Ahmed Qasir Ave., Argentine Square, Tehran, Iran; No. 129, 21's Khaled
Eslamboli, No. 1 Building, Tehran, Iran; Export Development Building, Next to the 15th Alley, Bokharest Street, Argentina Square, Tehran, Iran; No. 26,
Tosee Tower, Arzhantine Square, P.O. Box 15875-5964, Tehran 15139, Iran; No. 4, Gandi Ave., Tehran 1516747913, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 86936 (Iran) issued 10 Jul 1991; all offices worldwide [IRAN].
BANK TOSEH SADERAT IRAN (a.k.a. BANK TOWSEEH SADERAT IRAN; a.k.a. BANK TOWSEH SADERAT IRAN; a.k.a. EDBI; a.k.a. EXPORT
DEVELOPMENT BANK OF IRAN), Tose'e Tower, Corner of 15th St., Ahmed Qasir Ave., Argentine Square, Tehran, Iran; No. 129, 21's Khaled
Eslamboli, No. 1 Building, Tehran, Iran; Export Development Building, Next to the 15th Alley, Bokharest Street, Argentina Square, Tehran, Iran; No. 26,
Tosee Tower, Arzhantine Square, P.O. Box 15875-5964, Tehran 15139, Iran; No. 4, Gandi Ave., Tehran 1516747913, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 86936 (Iran) issued 10 Jul 1991; all offices worldwide [IRAN].
BANK TOWSEEH SADERAT IRAN (a.k.a. BANK TOSEH SADERAT IRAN; a.k.a. BANK TOWSEH SADERAT IRAN; a.k.a. EDBI; a.k.a. EXPORT
DEVELOPMENT BANK OF IRAN), Tose'e Tower, Corner of 15th St., Ahmed Qasir Ave., Argentine Square, Tehran, Iran; No. 129, 21's Khaled
Eslamboli, No. 1 Building, Tehran, Iran; Export Development Building, Next to the 15th Alley, Bokharest Street, Argentina Square, Tehran, Iran; No. 26,
Tosee Tower, Arzhantine Square, P.O. Box 15875-5964, Tehran 15139, Iran; No. 4, Gandi Ave., Tehran 1516747913, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 86936 (Iran) issued 10 Jul 1991; all offices worldwide [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 37/83
BANK TOWSEH SADERAT IRAN (a.k.a. BANK TOSEH SADERAT IRAN; a.k.a. BANK TOWSEEH SADERAT IRAN; a.k.a. EDBI; a.k.a. EXPORT
DEVELOPMENT BANK OF IRAN), Tose'e Tower, Corner of 15th St., Ahmed Qasir Ave., Argentine Square, Tehran, Iran; No. 129, 21's Khaled
Eslamboli, No. 1 Building, Tehran, Iran; Export Development Building, Next to the 15th Alley, Bokharest Street, Argentina Square, Tehran, Iran; No. 26,
Tosee Tower, Arzhantine Square, P.O. Box 15875-5964, Tehran 15139, Iran; No. 4, Gandi Ave., Tehran 1516747913, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 86936 (Iran) issued 10 Jul 1991; all offices worldwide [IRAN].
NATIONAL IRANIAN OIL COMPANY (a.k.a. NIOC), Hafez Crossing, Taleghani Avenue, P.O. Box 1863 and 2501, Tehran, Iran; National Iranian Oil
Company Building, Taleghani Avenue, Hafez Street, Tehran, Iran; Website www.nioc.ir; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices
worldwide [IRAN].
NIOC (a.k.a. NATIONAL IRANIAN OIL COMPANY), Hafez Crossing, Taleghani Avenue, P.O. Box 1863 and 2501, Tehran, Iran; National Iranian Oil
Company Building, Taleghani Avenue, Hafez Street, Tehran, Iran; Website www.nioc.ir; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices
worldwide [IRAN].
NAFTIRAN INTERTRADE CO. (NICO) LIMITED (a.k.a. NAFT IRAN INTERTRADE COMPANY LTD; a.k.a. NAFTIRAN INTERTRADE COMPANY
(NICO); a.k.a. NAFTIRAN INTERTRADE COMPANY LTD; a.k.a. NICO), 41, 1st Floor, International House, The Parade, St Helier JE2 3QQ, Jersey;
Petro Pars Building, Saadat Abad Ave, No 35, Farhang Blvd, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide
[IRAN] (Linked To: NIOC INTERNATIONAL AFFAIRS (LONDON) LIMITED).
NICO (a.k.a. NAFT IRAN INTERTRADE COMPANY LTD; a.k.a. NAFTIRAN INTERTRADE CO. (NICO) LIMITED; a.k.a. NAFTIRAN INTERTRADE
COMPANY (NICO); a.k.a. NAFTIRAN INTERTRADE COMPANY LTD), 41, 1st Floor, International House, The Parade, St Helier JE2 3QQ, Jersey;
Petro Pars Building, Saadat Abad Ave, No 35, Farhang Blvd, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide
[IRAN] (Linked To: NIOC INTERNATIONAL AFFAIRS (LONDON) LIMITED).
NAFT IRAN INTERTRADE COMPANY LTD (a.k.a. NAFTIRAN INTERTRADE CO. (NICO) LIMITED; a.k.a. NAFTIRAN INTERTRADE COMPANY
(NICO); a.k.a. NAFTIRAN INTERTRADE COMPANY LTD; a.k.a. NICO), 41, 1st Floor, International House, The Parade, St Helier JE2 3QQ, Jersey;
Petro Pars Building, Saadat Abad Ave, No 35, Farhang Blvd, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide
[IRAN] (Linked To: NIOC INTERNATIONAL AFFAIRS (LONDON) LIMITED).
NAFTIRAN INTERTRADE COMPANY (NICO) (a.k.a. NAFT IRAN INTERTRADE COMPANY LTD; a.k.a. NAFTIRAN INTERTRADE CO. (NICO)
LIMITED; a.k.a. NAFTIRAN INTERTRADE COMPANY LTD; a.k.a. NICO), 41, 1st Floor, International House, The Parade, St Helier JE2 3QQ, Jersey;
Petro Pars Building, Saadat Abad Ave, No 35, Farhang Blvd, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide
[IRAN] (Linked To: NIOC INTERNATIONAL AFFAIRS (LONDON) LIMITED).
NAFTIRAN INTERTRADE COMPANY LTD (a.k.a. NAFT IRAN INTERTRADE COMPANY LTD; a.k.a. NAFTIRAN INTERTRADE CO. (NICO) LIMITED;
a.k.a. NAFTIRAN INTERTRADE COMPANY (NICO); a.k.a. NICO), 41, 1st Floor, International House, The Parade, St Helier JE2 3QQ, Jersey; Petro
Pars Building, Saadat Abad Ave, No 35, Farhang Blvd, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide
[IRAN] (Linked To: NIOC INTERNATIONAL AFFAIRS (LONDON) LIMITED).
NAFTIRAN INTERTRADE CO. (NICO) SARL (a.k.a. NICO), 6, Avenue de la Tour-Haldimand, Pully, VD 1009, Switzerland; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
NICO (a.k.a. NAFTIRAN INTERTRADE CO. (NICO) SARL), 6, Avenue de la Tour-Haldimand, Pully, VD 1009, Switzerland; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
BANK TORGOVOY KAPITAL ZAO (a.k.a. TC BANK; a.k.a. TK BANK; a.k.a. TK BANK ZAO; a.k.a. TORGOVY KAPITAL (TK BANK); a.k.a. TRADE
CAPITAL BANK; a.k.a. TRADE CAPITAL BANK (TC BANK); a.k.a. ZAO BANK TORGOVY KAPITAL), 3 Kozlova Street, Minsk 220005, Belarus;
SWIFT/BIC BBTKBY2X; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 30 (Belarus); all offices worldwide [IRAN].
ZAO BANK TORGOVY KAPITAL (a.k.a. BANK TORGOVOY KAPITAL ZAO; a.k.a. TC BANK; a.k.a. TK BANK; a.k.a. TK BANK ZAO; a.k.a. TORGOVY
KAPITAL (TK BANK); a.k.a. TRADE CAPITAL BANK; a.k.a. TRADE CAPITAL BANK (TC BANK)), 3 Kozlova Street, Minsk 220005, Belarus;
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 38/83
SWIFT/BIC BBTKBY2X; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 30 (Belarus); all offices worldwide [IRAN].
TRADE CAPITAL BANK (a.k.a. BANK TORGOVOY KAPITAL ZAO; a.k.a. TC BANK; a.k.a. TK BANK; a.k.a. TK BANK ZAO; a.k.a. TORGOVY
KAPITAL (TK BANK); a.k.a. TRADE CAPITAL BANK (TC BANK); a.k.a. ZAO BANK TORGOVY KAPITAL), 3 Kozlova Street, Minsk 220005, Belarus;
SWIFT/BIC BBTKBY2X; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 30 (Belarus); all offices worldwide [IRAN].
TRADE CAPITAL BANK (TC BANK) (a.k.a. BANK TORGOVOY KAPITAL ZAO; a.k.a. TC BANK; a.k.a. TK BANK; a.k.a. TK BANK ZAO; a.k.a.
TORGOVY KAPITAL (TK BANK); a.k.a. TRADE CAPITAL BANK; a.k.a. ZAO BANK TORGOVY KAPITAL), 3 Kozlova Street, Minsk 220005, Belarus;
SWIFT/BIC BBTKBY2X; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 30 (Belarus); all offices worldwide [IRAN].
TK BANK ZAO (a.k.a. BANK TORGOVOY KAPITAL ZAO; a.k.a. TC BANK; a.k.a. TK BANK; a.k.a. TORGOVY KAPITAL (TK BANK); a.k.a. TRADE
CAPITAL BANK; a.k.a. TRADE CAPITAL BANK (TC BANK); a.k.a. ZAO BANK TORGOVY KAPITAL), 3 Kozlova Street, Minsk 220005, Belarus;
SWIFT/BIC BBTKBY2X; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 30 (Belarus); all offices worldwide [IRAN].
TORGOVY KAPITAL (TK BANK) (a.k.a. BANK TORGOVOY KAPITAL ZAO; a.k.a. TC BANK; a.k.a. TK BANK; a.k.a. TK BANK ZAO; a.k.a. TRADE
CAPITAL BANK; a.k.a. TRADE CAPITAL BANK (TC BANK); a.k.a. ZAO BANK TORGOVY KAPITAL), 3 Kozlova Street, Minsk 220005, Belarus;
SWIFT/BIC BBTKBY2X; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 30 (Belarus); all offices worldwide [IRAN].
TC BANK (a.k.a. BANK TORGOVOY KAPITAL ZAO; a.k.a. TK BANK; a.k.a. TK BANK ZAO; a.k.a. TORGOVY KAPITAL (TK BANK); a.k.a. TRADE
CAPITAL BANK; a.k.a. TRADE CAPITAL BANK (TC BANK); a.k.a. ZAO BANK TORGOVY KAPITAL), 3 Kozlova Street, Minsk 220005, Belarus;
SWIFT/BIC BBTKBY2X; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 30 (Belarus); all offices worldwide [IRAN].
TK BANK (a.k.a. BANK TORGOVOY KAPITAL ZAO; a.k.a. TC BANK; a.k.a. TK BANK ZAO; a.k.a. TORGOVY KAPITAL (TK BANK); a.k.a. TRADE
CAPITAL BANK; a.k.a. TRADE CAPITAL BANK (TC BANK); a.k.a. ZAO BANK TORGOVY KAPITAL), 3 Kozlova Street, Minsk 220005, Belarus;
SWIFT/BIC BBTKBY2X; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 30 (Belarus); all offices worldwide [IRAN].
IRANIAN MINES AND MINING INDUSTRIES DEVELOPMENT AND RENOVATION ORGANIZATION (a.k.a. IMIDRO; a.k.a. IRAN MINING
INDUSTRIES DEVELOPMENT AND RENOVATION ORGANIZATION; a.k.a. IRANIAN MINES AND MINERAL INDUSTRIES DEVELOPMENT AND
RENOVATION), No. 39, Sepahbod Gharani Avenue, Ferdousi Square, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices
worldwide [IRAN].
IMIDRO (a.k.a. IRAN MINING INDUSTRIES DEVELOPMENT AND RENOVATION ORGANIZATION; a.k.a. IRANIAN MINES AND MINERAL
INDUSTRIES DEVELOPMENT AND RENOVATION; a.k.a. IRANIAN MINES AND MINING INDUSTRIES DEVELOPMENT AND RENOVATION
ORGANIZATION), No. 39, Sepahbod Gharani Avenue, Ferdousi Square, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices
worldwide [IRAN].
IRAN MINING INDUSTRIES DEVELOPMENT AND RENOVATION ORGANIZATION (a.k.a. IMIDRO; a.k.a. IRANIAN MINES AND MINERAL
INDUSTRIES DEVELOPMENT AND RENOVATION; a.k.a. IRANIAN MINES AND MINING INDUSTRIES DEVELOPMENT AND RENOVATION
ORGANIZATION), No. 39, Sepahbod Gharani Avenue, Ferdousi Square, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices
worldwide [IRAN].
IRANIAN MINES AND MINERAL INDUSTRIES DEVELOPMENT AND RENOVATION (a.k.a. IMIDRO; a.k.a. IRAN MINING INDUSTRIES
DEVELOPMENT AND RENOVATION ORGANIZATION; a.k.a. IRANIAN MINES AND MINING INDUSTRIES DEVELOPMENT AND RENOVATION
ORGANIZATION), No. 39, Sepahbod Gharani Avenue, Ferdousi Square, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices
worldwide [IRAN].
ASCOTEC HOLDING GMBH (f.k.a. AHWAZ STEEL COMMERCIAL & TECHNICAL SERVICE GMBH ASCOTEC; f.k.a. AHWAZ STEEL
COMMERCIAL AND TECHNICAL SERVICE GMBH ASCOTEC; a.k.a. ASCOTEC GMBH), Tersteegen Strasse 10, Dusseldorf 40474, Germany;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB 26136 (Germany); all offices worldwide [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 39/83
ASCOTEC GMBH (f.k.a. AHWAZ STEEL COMMERCIAL & TECHNICAL SERVICE GMBH ASCOTEC; f.k.a. AHWAZ STEEL COMMERCIAL AND
TECHNICAL SERVICE GMBH ASCOTEC; a.k.a. ASCOTEC HOLDING GMBH), Tersteegen Strasse 10, Dusseldorf 40474, Germany; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB 26136 (Germany); all offices worldwide [IRAN].
AHWAZ STEEL COMMERCIAL & TECHNICAL SERVICE GMBH ASCOTEC (f.k.a. AHWAZ STEEL COMMERCIAL AND TECHNICAL SERVICE
GMBH ASCOTEC; a.k.a. ASCOTEC GMBH; a.k.a. ASCOTEC HOLDING GMBH), Tersteegen Strasse 10, Dusseldorf 40474, Germany; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB 26136 (Germany); all offices worldwide [IRAN].
AHWAZ STEEL COMMERCIAL AND TECHNICAL SERVICE GMBH ASCOTEC (f.k.a. AHWAZ STEEL COMMERCIAL & TECHNICAL SERVICE
GMBH ASCOTEC; a.k.a. ASCOTEC GMBH; a.k.a. ASCOTEC HOLDING GMBH), Tersteegen Strasse 10, Dusseldorf 40474, Germany; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB 26136 (Germany); all offices worldwide [IRAN].
ASCOTEC JAPAN K.K., 8th Floor, Shiba East Building, 2-3-9 Shiba, Minato-ku, Tokyo 105-0014, Japan; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
METAL & MINERAL TRADE S.A.R.L. (a.k.a. METAL & MINERAL TRADE (MMT); a.k.a. METAL AND MINERAL TRADE (MMT); a.k.a. METAL AND
MINERAL TRADE S.A.R.L.; a.k.a. MMT LUXEMBURG; a.k.a. MMT SARL), 11b, Boulevard Joseph II L-1840, Luxembourg; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID B 59411 (Luxembourg); all offices worldwide [IRAN].
METAL & MINERAL TRADE (MMT) (a.k.a. METAL & MINERAL TRADE S.A.R.L.; a.k.a. METAL AND MINERAL TRADE (MMT); a.k.a. METAL AND
MINERAL TRADE S.A.R.L.; a.k.a. MMT LUXEMBURG; a.k.a. MMT SARL), 11b, Boulevard Joseph II L-1840, Luxembourg; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID B 59411 (Luxembourg); all offices worldwide [IRAN].
MMT LUXEMBURG (a.k.a. METAL & MINERAL TRADE (MMT); a.k.a. METAL & MINERAL TRADE S.A.R.L.; a.k.a. METAL AND MINERAL TRADE
(MMT); a.k.a. METAL AND MINERAL TRADE S.A.R.L.; a.k.a. MMT SARL), 11b, Boulevard Joseph II L-1840, Luxembourg; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID B 59411 (Luxembourg); all offices worldwide [IRAN].
MMT SARL (a.k.a. METAL & MINERAL TRADE (MMT); a.k.a. METAL & MINERAL TRADE S.A.R.L.; a.k.a. METAL AND MINERAL TRADE (MMT);
a.k.a. METAL AND MINERAL TRADE S.A.R.L.; a.k.a. MMT LUXEMBURG), 11b, Boulevard Joseph II L-1840, Luxembourg; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID B 59411 (Luxembourg); all offices worldwide [IRAN].
METAL AND MINERAL TRADE S.A.R.L. (a.k.a. METAL & MINERAL TRADE (MMT); a.k.a. METAL & MINERAL TRADE S.A.R.L.; a.k.a. METAL AND
MINERAL TRADE (MMT); a.k.a. MMT LUXEMBURG; a.k.a. MMT SARL), 11b, Boulevard Joseph II L-1840, Luxembourg; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID B 59411 (Luxembourg); all offices worldwide [IRAN].
METAL AND MINERAL TRADE (MMT) (a.k.a. METAL & MINERAL TRADE (MMT); a.k.a. METAL & MINERAL TRADE S.A.R.L.; a.k.a. METAL AND
MINERAL TRADE S.A.R.L.; a.k.a. MMT LUXEMBURG; a.k.a. MMT SARL), 11b, Boulevard Joseph II L-1840, Luxembourg; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID B 59411 (Luxembourg); all offices worldwide [IRAN].
IRASCO S.R.L. (a.k.a. IRASCO ITALY), Via Di Francia 3, Genoa 16149, Italy; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order
13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID
GE 348075 (Italy); all offices worldwide [IRAN].
IRASCO ITALY (a.k.a. IRASCO S.R.L.), Via Di Francia 3, Genoa 16149, Italy; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order
13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID
GE 348075 (Italy); all offices worldwide [IRAN].
MINES AND METALS ENGINEERING GMBH (a.k.a. "M.M.E."), Georg-Glock-Str. 3, Dusseldorf 40474, Germany; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 40/83
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB 34095 (Germany); all offices worldwide [IRAN].
"M.M.E." (a.k.a. MINES AND METALS ENGINEERING GMBH), Georg-Glock-Str. 3, Dusseldorf 40474, Germany; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB 34095 (Germany); all offices worldwide [IRAN].
ASCOTEC STEEL TRADING GMBH (a.k.a. ASCOTEC STEEL), Tersteegenstr. 10, Dusseldorf 40474, Germany; Georg-Glock-Str. 3, Dusseldorf
40474, Germany; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID HRB 48319 (Germany); all offices worldwide
[IRAN].
ASCOTEC STEEL (a.k.a. ASCOTEC STEEL TRADING GMBH), Tersteegenstr. 10, Dusseldorf 40474, Germany; Georg-Glock-Str. 3, Dusseldorf
40474, Germany; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID HRB 48319 (Germany); all offices worldwide
[IRAN].
ASCOTEC MINERAL & MACHINERY GMBH (a.k.a. ASCOTEC MINERAL AND MACHINERY GMBH; f.k.a. BREYELLER KALTBAND GMBH),
Tersteegenstr. 10, Dusseldorf 40474, Germany; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID HRB 55668 (Germany); all
offices worldwide [IRAN].
BREYELLER KALTBAND GMBH (a.k.a. ASCOTEC MINERAL & MACHINERY GMBH; a.k.a. ASCOTEC MINERAL AND MACHINERY GMBH),
Tersteegenstr. 10, Dusseldorf 40474, Germany; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID HRB 55668 (Germany); all
offices worldwide [IRAN].
ASCOTEC MINERAL AND MACHINERY GMBH (a.k.a. ASCOTEC MINERAL & MACHINERY GMBH; f.k.a. BREYELLER KALTBAND GMBH),
Tersteegenstr. 10, Dusseldorf 40474, Germany; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID HRB 55668 (Germany); all
offices worldwide [IRAN].
ASCOTEC SCIENCE & TECHNOLOGY GMBH (a.k.a. ASCOTEC SCIENCE AND TECHNOLOGY GMBH), Tersteegenstrasse 10, Dusseldorf D 40474,
Germany; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID HRB 58745 (Germany); all offices worldwide
[IRAN].
ASCOTEC SCIENCE AND TECHNOLOGY GMBH (a.k.a. ASCOTEC SCIENCE & TECHNOLOGY GMBH), Tersteegenstrasse 10, Dusseldorf D 40474,
Germany; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID HRB 58745 (Germany); all offices worldwide
[IRAN].
BREYELLER STAHL TECHNOLOGY GMBH & CO. KG (a.k.a. BREYELLER STAHL TECHNOLOGY GMBH AND CO. KG; f.k.a. ROETZEL-STAHL
GMBH & CO. KG; f.k.a. ROETZEL-STAHL GMBH AND CO. KG), Josefstrasse 82, Nettetal 41334, Germany; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRA 4528 (Germany); all offices worldwide [IRAN].
ROETZEL-STAHL GMBH & CO. KG (a.k.a. BREYELLER STAHL TECHNOLOGY GMBH & CO. KG; a.k.a. BREYELLER STAHL TECHNOLOGY
GMBH AND CO. KG; f.k.a. ROETZEL-STAHL GMBH AND CO. KG), Josefstrasse 82, Nettetal 41334, Germany; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRA 4528 (Germany); all offices worldwide [IRAN].
BREYELLER STAHL TECHNOLOGY GMBH AND CO. KG (a.k.a. BREYELLER STAHL TECHNOLOGY GMBH & CO. KG; f.k.a. ROETZEL-STAHL
GMBH & CO. KG; f.k.a. ROETZEL-STAHL GMBH AND CO. KG), Josefstrasse 82, Nettetal 41334, Germany; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRA 4528 (Germany); all offices worldwide [IRAN].
ROETZEL-STAHL GMBH AND CO. KG (a.k.a. BREYELLER STAHL TECHNOLOGY GMBH & CO. KG; a.k.a. BREYELLER STAHL TECHNOLOGY
GMBH AND CO. KG; f.k.a. ROETZEL-STAHL GMBH & CO. KG), Josefstrasse 82, Nettetal 41334, Germany; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRA 4528 (Germany); all offices worldwide [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 41/83
NATIONAL PETROCHEMICAL COMPANY (a.k.a. "NPC"), No. 104, North Sheikh Bahaei Blvd., Molla Sadra Ave., Tehran, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
"NPC" (a.k.a. NATIONAL PETROCHEMICAL COMPANY), No. 104, North Sheikh Bahaei Blvd., Molla Sadra Ave., Tehran, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
IRAN PETROCHEMICAL COMMERCIAL COMPANY (a.k.a. PETROCHEMICAL COMMERCIAL COMPANY; a.k.a. SHERKATE BASARGANI
PETROCHEMIE (SAHAMI KHASS); a.k.a. SHERKATE BAZARGANI PETRCHEMIE; a.k.a. "IPCC"; a.k.a. "PCC"), No. 1339, Vali Nejad Alley, Vali-e-
Asr St., Vanak Sq., Tehran, Iran; INONU CAD. SUMER Sok., Zitas Bloklari C.2 Bloc D.H, Kozyatagi, Kadikoy, Istanbul, Turkey; Topcu Ibrahim Sokak
No: 13 D: 7 Icerenkoy-Kadikoy, Istanbul, Turkey; 99-A, Maker Tower F, 9th Floor, Cuffe Parade, Colabe, Mumbai 400 005, India; No. 1014, Doosan
We've Pavilion, 58, Soosong-Dong, Jongno-Gu, Seoul, Korea, South; Office No. 707, No. 10, Chao Waidajie, Chao Tang District, Beijing 100020,
China; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
SHERKATE BAZARGANI PETRCHEMIE (a.k.a. IRAN PETROCHEMICAL COMMERCIAL COMPANY; a.k.a. PETROCHEMICAL COMMERCIAL
COMPANY; a.k.a. SHERKATE BASARGANI PETROCHEMIE (SAHAMI KHASS); a.k.a. "IPCC"; a.k.a. "PCC"), No. 1339, Vali Nejad Alley, Vali-e-Asr
St., Vanak Sq., Tehran, Iran; INONU CAD. SUMER Sok., Zitas Bloklari C.2 Bloc D.H, Kozyatagi, Kadikoy, Istanbul, Turkey; Topcu Ibrahim Sokak No:
13 D: 7 Icerenkoy-Kadikoy, Istanbul, Turkey; 99-A, Maker Tower F, 9th Floor, Cuffe Parade, Colabe, Mumbai 400 005, India; No. 1014, Doosan We've
Pavilion, 58, Soosong-Dong, Jongno-Gu, Seoul, Korea, South; Office No. 707, No. 10, Chao Waidajie, Chao Tang District, Beijing 100020, China;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
SHERKATE BASARGANI PETROCHEMIE (SAHAMI KHASS) (a.k.a. IRAN PETROCHEMICAL COMMERCIAL COMPANY; a.k.a. PETROCHEMICAL
COMMERCIAL COMPANY; a.k.a. SHERKATE BAZARGANI PETRCHEMIE; a.k.a. "IPCC"; a.k.a. "PCC"), No. 1339, Vali Nejad Alley, Vali-e-Asr St.,
Vanak Sq., Tehran, Iran; INONU CAD. SUMER Sok., Zitas Bloklari C.2 Bloc D.H, Kozyatagi, Kadikoy, Istanbul, Turkey; Topcu Ibrahim Sokak No: 13 D:
7 Icerenkoy-Kadikoy, Istanbul, Turkey; 99-A, Maker Tower F, 9th Floor, Cuffe Parade, Colabe, Mumbai 400 005, India; No. 1014, Doosan We've
Pavilion, 58, Soosong-Dong, Jongno-Gu, Seoul, Korea, South; Office No. 707, No. 10, Chao Waidajie, Chao Tang District, Beijing 100020, China;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
PETROCHEMICAL COMMERCIAL COMPANY (a.k.a. IRAN PETROCHEMICAL COMMERCIAL COMPANY; a.k.a. SHERKATE BASARGANI
PETROCHEMIE (SAHAMI KHASS); a.k.a. SHERKATE BAZARGANI PETRCHEMIE; a.k.a. "IPCC"; a.k.a. "PCC"), No. 1339, Vali Nejad Alley, Vali-e-
Asr St., Vanak Sq., Tehran, Iran; INONU CAD. SUMER Sok., Zitas Bloklari C.2 Bloc D.H, Kozyatagi, Kadikoy, Istanbul, Turkey; Topcu Ibrahim Sokak
No: 13 D: 7 Icerenkoy-Kadikoy, Istanbul, Turkey; 99-A, Maker Tower F, 9th Floor, Cuffe Parade, Colabe, Mumbai 400 005, India; No. 1014, Doosan
We've Pavilion, 58, Soosong-Dong, Jongno-Gu, Seoul, Korea, South; Office No. 707, No. 10, Chao Waidajie, Chao Tang District, Beijing 100020,
China; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
"IPCC" (a.k.a. IRAN PETROCHEMICAL COMMERCIAL COMPANY; a.k.a. PETROCHEMICAL COMMERCIAL COMPANY; a.k.a. SHERKATE
BASARGANI PETROCHEMIE (SAHAMI KHASS); a.k.a. SHERKATE BAZARGANI PETRCHEMIE; a.k.a. "PCC"), No. 1339, Vali Nejad Alley, Vali-e-
Asr St., Vanak Sq., Tehran, Iran; INONU CAD. SUMER Sok., Zitas Bloklari C.2 Bloc D.H, Kozyatagi, Kadikoy, Istanbul, Turkey; Topcu Ibrahim Sokak
No: 13 D: 7 Icerenkoy-Kadikoy, Istanbul, Turkey; 99-A, Maker Tower F, 9th Floor, Cuffe Parade, Colabe, Mumbai 400 005, India; No. 1014, Doosan
We've Pavilion, 58, Soosong-Dong, Jongno-Gu, Seoul, Korea, South; Office No. 707, No. 10, Chao Waidajie, Chao Tang District, Beijing 100020,
China; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
"PCC" (a.k.a. IRAN PETROCHEMICAL COMMERCIAL COMPANY; a.k.a. PETROCHEMICAL COMMERCIAL COMPANY; a.k.a. SHERKATE
BASARGANI PETROCHEMIE (SAHAMI KHASS); a.k.a. SHERKATE BAZARGANI PETRCHEMIE; a.k.a. "IPCC"), No. 1339, Vali Nejad Alley, Vali-e-
Asr St., Vanak Sq., Tehran, Iran; INONU CAD. SUMER Sok., Zitas Bloklari C.2 Bloc D.H, Kozyatagi, Kadikoy, Istanbul, Turkey; Topcu Ibrahim Sokak
No: 13 D: 7 Icerenkoy-Kadikoy, Istanbul, Turkey; 99-A, Maker Tower F, 9th Floor, Cuffe Parade, Colabe, Mumbai 400 005, India; No. 1014, Doosan
We've Pavilion, 58, Soosong-Dong, Jongno-Gu, Seoul, Korea, South; Office No. 707, No. 10, Chao Waidajie, Chao Tang District, Beijing 100020,
China; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
NPC INTERNATIONAL LIMITED (a.k.a. N P C INTERNATIONAL LTD; a.k.a. NPC INTERNATIONAL COMPANY), 5th Floor NIOC House, 4 Victoria
Street, London SW1H 0NE, United Kingdom; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; UK Company Number 02696754 (United
Kingdom); all offices worldwide [IRAN].
NPC INTERNATIONAL COMPANY (a.k.a. N P C INTERNATIONAL LTD; a.k.a. NPC INTERNATIONAL LIMITED), 5th Floor NIOC House, 4 Victoria
Street, London SW1H 0NE, United Kingdom; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 42/83
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; UK Company Number 02696754 (United
Kingdom); all offices worldwide [IRAN].
N P C INTERNATIONAL LTD (a.k.a. NPC INTERNATIONAL COMPANY; a.k.a. NPC INTERNATIONAL LIMITED), 5th Floor NIOC House, 4 Victoria
Street, London SW1H 0NE, United Kingdom; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; UK Company Number 02696754 (United
Kingdom); all offices worldwide [IRAN].
INTRA CHEM TRADING GMBH (a.k.a. INTRA-CHEM TRADING CO. (GMBH)), Schottweg 3, Hamburg 22087, Germany; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB48416 (Germany); all offices worldwide [IRAN].
INTRA-CHEM TRADING CO. (GMBH) (a.k.a. INTRA CHEM TRADING GMBH), Schottweg 3, Hamburg 22087, Germany; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB48416 (Germany); all offices worldwide [IRAN].
PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL (a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LIMITED;
a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LTD; a.k.a. PETROCHEMICAL TRADING COMPANY LIMITED; a.k.a.
"PCCI"), 41, 1st Floor, International House, The Parade, St. Helier JE2 3QQ, Jersey; Ave. 54, Yimpash Business Center, No. 506, 507, Ashkhabad
744036, Turkmenistan; P.O. Box 261539, Jebel Ali, Dubai, United Arab Emirates; No. 21 End of 9th St, Gandi Ave, Tehran, Iran; 21, Africa Boulevard,
Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block
the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 77283 (Jersey); all offices worldwide [IRAN].
PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LTD (a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL; a.k.a.
PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LIMITED; a.k.a. PETROCHEMICAL TRADING COMPANY LIMITED; a.k.a. "PCCI"),
41, 1st Floor, International House, The Parade, St. Helier JE2 3QQ, Jersey; Ave. 54, Yimpash Business Center, No. 506, 507, Ashkhabad 744036,
Turkmenistan; P.O. Box 261539, Jebel Ali, Dubai, United Arab Emirates; No. 21 End of 9th St, Gandi Ave, Tehran, Iran; 21, Africa Boulevard, Tehran,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 77283 (Jersey); all offices worldwide [IRAN].
PETROCHEMICAL TRADING COMPANY LIMITED (a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL; a.k.a.
PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LIMITED; a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL
LTD; a.k.a. "PCCI"), 41, 1st Floor, International House, The Parade, St. Helier JE2 3QQ, Jersey; Ave. 54, Yimpash Business Center, No. 506, 507,
Ashkhabad 744036, Turkmenistan; P.O. Box 261539, Jebel Ali, Dubai, United Arab Emirates; No. 21 End of 9th St, Gandi Ave, Tehran, Iran; 21, Africa
Boulevard, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 77283 (Jersey); all offices worldwide [IRAN].
"PCCI" (a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL; a.k.a. PETROCHEMICAL COMMERCIAL COMPANY
INTERNATIONAL LIMITED; a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LTD; a.k.a. PETROCHEMICAL TRADING
COMPANY LIMITED), 41, 1st Floor, International House, The Parade, St. Helier JE2 3QQ, Jersey; Ave. 54, Yimpash Business Center, No. 506, 507,
Ashkhabad 744036, Turkmenistan; P.O. Box 261539, Jebel Ali, Dubai, United Arab Emirates; No. 21 End of 9th St, Gandi Ave, Tehran, Iran; 21, Africa
Boulevard, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 77283 (Jersey); all offices worldwide [IRAN].
PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LIMITED (a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL;
a.k.a. PETROCHEMICAL COMMERCIAL COMPANY INTERNATIONAL LTD; a.k.a. PETROCHEMICAL TRADING COMPANY LIMITED; a.k.a.
"PCCI"), 41, 1st Floor, International House, The Parade, St. Helier JE2 3QQ, Jersey; Ave. 54, Yimpash Business Center, No. 506, 507, Ashkhabad
744036, Turkmenistan; P.O. Box 261539, Jebel Ali, Dubai, United Arab Emirates; No. 21 End of 9th St, Gandi Ave, Tehran, Iran; 21, Africa Boulevard,
Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block
the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 77283 (Jersey); all offices worldwide [IRAN].
P.C.C. (SINGAPORE) PRIVATE LIMITED (a.k.a. P.C.C. SINGAPORE BRANCH; a.k.a. PCC SINGAPORE PTE LTD), 78 Shenton Way, #08-02 079120,
Singapore; 78 Shenton Way, 26-02A Lippo Centre 079120, Singapore; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID
199708410K (Singapore); all offices worldwide [IRAN].
PCC SINGAPORE PTE LTD (a.k.a. P.C.C. (SINGAPORE) PRIVATE LIMITED; a.k.a. P.C.C. SINGAPORE BRANCH), 78 Shenton Way, #08-02 079120,
Singapore; 78 Shenton Way, 26-02A Lippo Centre 079120, Singapore; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID
199708410K (Singapore); all offices worldwide [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 43/83
P.C.C. SINGAPORE BRANCH (a.k.a. P.C.C. (SINGAPORE) PRIVATE LIMITED; a.k.a. PCC SINGAPORE PTE LTD), 78 Shenton Way, #08-02 079120,
Singapore; 78 Shenton Way, 26-02A Lippo Centre 079120, Singapore; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID
199708410K (Singapore); all offices worldwide [IRAN].
PETROCHEMICAL COMMERCIAL COMPANY FZE (a.k.a. PCC FZE), 1703, 17th Floor, Dubai World Trade Center Tower, Sheikh Zayed Road, Dubai,
United Arab Emirates; Office No. 99-A, Maker Tower "F" 9th Floor Cutte Pavade, Colabe, Mumbai 700005, India; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
PCC FZE (a.k.a. PETROCHEMICAL COMMERCIAL COMPANY FZE), 1703, 17th Floor, Dubai World Trade Center Tower, Sheikh Zayed Road, Dubai,
United Arab Emirates; Office No. 99-A, Maker Tower "F" 9th Floor Cutte Pavade, Colabe, Mumbai 700005, India; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
PETROCHEMICAL COMMERCIAL COMPANY (U.K.) LIMITED (a.k.a. PCC (UK); a.k.a. PCC UK; a.k.a. PCC UK LTD), 4 Victoria Street, London
SW1H 0NE, United Kingdom; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; UK Company Number 02647333 (United Kingdom); all
offices worldwide [IRAN].
PCC (UK) (a.k.a. PCC UK; a.k.a. PCC UK LTD; a.k.a. PETROCHEMICAL COMMERCIAL COMPANY (U.K.) LIMITED), 4 Victoria Street, London
SW1H 0NE, United Kingdom; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; UK Company Number 02647333 (United Kingdom); all
offices worldwide [IRAN].
PCC UK (a.k.a. PCC (UK); a.k.a. PCC UK LTD; a.k.a. PETROCHEMICAL COMMERCIAL COMPANY (U.K.) LIMITED), 4 Victoria Street, London
SW1H 0NE, United Kingdom; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; UK Company Number 02647333 (United Kingdom); all
offices worldwide [IRAN].
PCC UK LTD (a.k.a. PCC (UK); a.k.a. PCC UK; a.k.a. PETROCHEMICAL COMMERCIAL COMPANY (U.K.) LIMITED), 4 Victoria Street, London
SW1H 0NE, United Kingdom; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; UK Company Number 02647333 (United Kingdom); all
offices worldwide [IRAN].
IRAN FOREIGN INVESTMENT COMPANY (a.k.a. IFIC), No. 4, Saba Blvd., Africa Blvd., Tehran 19177, Iran; P.O. Box 19395-6947, Tehran, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
IFIC (a.k.a. IRAN FOREIGN INVESTMENT COMPANY), No. 4, Saba Blvd., Africa Blvd., Tehran 19177, Iran; P.O. Box 19395-6947, Tehran, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
IFIC HOLDING AG (a.k.a. IHAG), Koenigsallee 60 D, Dusseldorf 40212, Germany; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Registration ID HRB 48032 (Germany); all offices worldwide [IRAN].
IHAG (a.k.a. IFIC HOLDING AG), Koenigsallee 60 D, Dusseldorf 40212, Germany; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Registration ID HRB 48032 (Germany); all offices worldwide [IRAN].
IHAG TRADING GMBH, Koenigsallee 60 D, Dusseldorf 40212, Germany; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID HRB
37918 (Germany); all offices worldwide [IRAN].
NATIONAL IRANIAN OIL COMPANY PTE LTD, 7 Temasek Boulevard #07-02, Suntec Tower One 038987, Singapore; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 199004388C (Singapore); all offices worldwide [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 44/83
IRAN INSURANCE COMPANY (a.k.a. BIMEH IRAN), 107 Dr Fatemi Avenue, Tehran 14155/6363, Iran; Abdolaziz-Al-Masaeed Building, Sheikh
Maktoom St., Deira, P.O. Box 2004, Dubai, United Arab Emirates; P.O. Box 1867, Al Ain, Abu Dhabi, United Arab Emirates; P.O. Box 3281, Abu Dhabi,
United Arab Emirates; P.O. Box 1666, Sharjah, United Arab Emirates; P.O. Box 849, Ras-Al-Khaimah, United Arab Emirates; P.O. Box 417, Muscat
113, Oman; P.O. Box 676, Salalah 211, Oman; P.O. Box 995, Manama, Bahrain; Al-Lami Center, Ali-Bin-Abi Taleb St. Sharafia, P.O. Box 11210,
Jeddah 21453, Saudi Arabia; Al Alia Center, Salaheddine Rd., Al Malaz, P.O. Box 21944, Riyadh 11485, Saudi Arabia; Al Rajhi Bldg., 3rd Floor, Suite
23, Dhahran St., P.O. Box 1305, Dammam 31431, Saudi Arabia; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
BIMEH IRAN (a.k.a. IRAN INSURANCE COMPANY), 107 Dr Fatemi Avenue, Tehran 14155/6363, Iran; Abdolaziz-Al-Masaeed Building, Sheikh
Maktoom St., Deira, P.O. Box 2004, Dubai, United Arab Emirates; P.O. Box 1867, Al Ain, Abu Dhabi, United Arab Emirates; P.O. Box 3281, Abu Dhabi,
United Arab Emirates; P.O. Box 1666, Sharjah, United Arab Emirates; P.O. Box 849, Ras-Al-Khaimah, United Arab Emirates; P.O. Box 417, Muscat
113, Oman; P.O. Box 676, Salalah 211, Oman; P.O. Box 995, Manama, Bahrain; Al-Lami Center, Ali-Bin-Abi Taleb St. Sharafia, P.O. Box 11210,
Jeddah 21453, Saudi Arabia; Al Alia Center, Salaheddine Rd., Al Malaz, P.O. Box 21944, Riyadh 11485, Saudi Arabia; Al Rajhi Bldg., 3rd Floor, Suite
23, Dhahran St., P.O. Box 1305, Dammam 31431, Saudi Arabia; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
BIMEH IRAN INSURANCE COMPANY (U.K.) LIMITED (a.k.a. BIUK), 4/5 Fenchurch Buildings, London EC3M 5HN, United Kingdom; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; UK Company Number 01223433 (United Kingdom); all offices worldwide [IRAN].
BIUK (a.k.a. BIMEH IRAN INSURANCE COMPANY (U.K.) LIMITED), 4/5 Fenchurch Buildings, London EC3M 5HN, United Kingdom; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; UK Company Number 01223433 (United Kingdom); all offices worldwide [IRAN].
PETROPARS LTD. (a.k.a. PETROPARS LIMITED; a.k.a. "PPL"), No. 35, Farhang Blvd., Saadat Abad, Tehran, Iran; Calle La Guairita, Centro
Profesional Eurobuilding, Piso 8, Oficina 8E, Chuao, Caracas 1060, Venezuela; P.O. Box 3136, Road Town, Tortola, Virgin Islands, British; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
PETROPARS LIMITED (a.k.a. PETROPARS LTD.; a.k.a. "PPL"), No. 35, Farhang Blvd., Saadat Abad, Tehran, Iran; Calle La Guairita, Centro
Profesional Eurobuilding, Piso 8, Oficina 8E, Chuao, Caracas 1060, Venezuela; P.O. Box 3136, Road Town, Tortola, Virgin Islands, British; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
"PPL" (a.k.a. PETROPARS LIMITED; a.k.a. PETROPARS LTD.), No. 35, Farhang Blvd., Saadat Abad, Tehran, Iran; Calle La Guairita, Centro
Profesional Eurobuilding, Piso 8, Oficina 8E, Chuao, Caracas 1060, Venezuela; P.O. Box 3136, Road Town, Tortola, Virgin Islands, British; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
PETROPARS INTERNATIONAL FZE (a.k.a. PPI FZE), P.O. Box 72146, Dubai, United Arab Emirates; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
PPI FZE (a.k.a. PETROPARS INTERNATIONAL FZE), P.O. Box 72146, Dubai, United Arab Emirates; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
PETROPARS UK LIMITED, 47 Queen Anne Street, London W1G 9JG, United Kingdom; Additional Sanctions Information - Not on the SDN List and
Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; UK
Company Number 03503060 (United Kingdom); all offices worldwide [IRAN].
KALA LIMITED (a.k.a. KALA NAFT LONDON LTD), NIOC House, 4 Victoria Street, Westminster, London SW1H 0NE, United Kingdom; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; UK Company Number 01517853 (United Kingdom); all offices worldwide [IRAN].
KALA NAFT LONDON LTD (a.k.a. KALA LIMITED), NIOC House, 4 Victoria Street, Westminster, London SW1H 0NE, United Kingdom; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; UK Company Number 01517853 (United Kingdom); all offices worldwide [IRAN].
KALA PENSION TRUST LIMITED, C/O Kala Limited, N.I.O.C. House, 4 Victoria Street, London SW1H 0NE, United Kingdom; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 45/83
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; UK Company Number 01573317 (United Kingdom); all offices worldwide [IRAN].
IRANIAN OIL COMPANY (U.K.) LIMITED (a.k.a. IOC UK LTD), Riverside House, Riverside Drive, Aberdeen AB11 7LH, United Kingdom; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; UK Company Number 01019769 (United Kingdom); all offices worldwide [IRAN].
IOC UK LTD (a.k.a. IRANIAN OIL COMPANY (U.K.) LIMITED), Riverside House, Riverside Drive, Aberdeen AB11 7LH, United Kingdom; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; UK Company Number 01019769 (United Kingdom); all offices worldwide [IRAN].
NIOC INTERNATIONAL AFFAIRS (LONDON) LIMITED, NIOC House, 4 Victoria Street, London SW1H 0NE, United Kingdom; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; UK Company Number 02772297 (United Kingdom); all offices worldwide [IRAN].
NAFTIRAN TRADING SERVICES CO. (NTS) LIMITED, 47 Queen Anne Street, London W1G 9JG, United Kingdom; 6th Floor NIOC Ho, 4 Victoria St,
London SW1H 0NE, United Kingdom; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; UK Company Number 02600121 (United Kingdom); all
offices worldwide [IRAN].
PETROIRAN DEVELOPMENT COMPANY (PEDCO) LIMITED (a.k.a. PETRO IRAN DEVELOPMENT COMPANY; a.k.a. "PEDCO"), 41, 1st Floor,
International House, The Parade, St. Helier JE2 3QQ, Jersey; National Iranian Oil Company - PEDCO, P.O. Box 2965, Al Bathaa Tower, 9th Floor, Apt.
905, Al Buhaira Corniche, Sharjah, United Arab Emirates; P.O. Box 15875-6731, Tehran, Iran; No. 22, 7th Lane, Khalid Eslamboli Street, Shahid
Beheshti Avenue, Tehran, Iran; No. 102, Next to Shahid Amir Soheil Tabrizian Alley, Shahid Dastgerdi (Ex Zafar) Street, Shariati Street, Tehran
19199/45111, Iran; Kish Harbour, Bazargan Ferdos Warehouses, Kish Island, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Registration ID 67493 (Jersey); all offices worldwide [IRAN].
"PEDCO" (a.k.a. PETRO IRAN DEVELOPMENT COMPANY; a.k.a. PETROIRAN DEVELOPMENT COMPANY (PEDCO) LIMITED), 41, 1st Floor,
International House, The Parade, St. Helier JE2 3QQ, Jersey; National Iranian Oil Company - PEDCO, P.O. Box 2965, Al Bathaa Tower, 9th Floor, Apt.
905, Al Buhaira Corniche, Sharjah, United Arab Emirates; P.O. Box 15875-6731, Tehran, Iran; No. 22, 7th Lane, Khalid Eslamboli Street, Shahid
Beheshti Avenue, Tehran, Iran; No. 102, Next to Shahid Amir Soheil Tabrizian Alley, Shahid Dastgerdi (Ex Zafar) Street, Shariati Street, Tehran
19199/45111, Iran; Kish Harbour, Bazargan Ferdos Warehouses, Kish Island, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Registration ID 67493 (Jersey); all offices worldwide [IRAN].
PETRO IRAN DEVELOPMENT COMPANY (a.k.a. PETROIRAN DEVELOPMENT COMPANY (PEDCO) LIMITED; a.k.a. "PEDCO"), 41, 1st Floor,
International House, The Parade, St. Helier JE2 3QQ, Jersey; National Iranian Oil Company - PEDCO, P.O. Box 2965, Al Bathaa Tower, 9th Floor, Apt.
905, Al Buhaira Corniche, Sharjah, United Arab Emirates; P.O. Box 15875-6731, Tehran, Iran; No. 22, 7th Lane, Khalid Eslamboli Street, Shahid
Beheshti Avenue, Tehran, Iran; No. 102, Next to Shahid Amir Soheil Tabrizian Alley, Shahid Dastgerdi (Ex Zafar) Street, Shariati Street, Tehran
19199/45111, Iran; Kish Harbour, Bazargan Ferdos Warehouses, Kish Island, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Registration ID 67493 (Jersey); all offices worldwide [IRAN].
NICO ENGINEERING LIMITED, 41, 1st Floor, International House, The Parade, St. Helier JE2 3QQ, Jersey; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 75797 (Jersey); all offices worldwide [IRAN].
INDUSTRIAL DEVELOPMENT AND RENOVATION ORGANIZATION OF IRAN (a.k.a. IDRO; a.k.a. IRAN DEVELOPMENT & RENOVATION
ORGANIZATION COMPANY; a.k.a. IRAN DEVELOPMENT AND RENOVATION ORGANIZATION COMPANY; a.k.a. SAWZEMANE GOSTARESH VA
NOWSAZI SANAYE IRAN), Vali Asr Building, Jam e Jam Street, Vali Asr Avenue, Tehran 15815-3377, Iran; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
IRAN DEVELOPMENT & RENOVATION ORGANIZATION COMPANY (a.k.a. IDRO; a.k.a. INDUSTRIAL DEVELOPMENT AND RENOVATION
ORGANIZATION OF IRAN; a.k.a. IRAN DEVELOPMENT AND RENOVATION ORGANIZATION COMPANY; a.k.a. SAWZEMANE GOSTARESH VA
NOWSAZI SANAYE IRAN), Vali Asr Building, Jam e Jam Street, Vali Asr Avenue, Tehran 15815-3377, Iran; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
IDRO (a.k.a. INDUSTRIAL DEVELOPMENT AND RENOVATION ORGANIZATION OF IRAN; a.k.a. IRAN DEVELOPMENT & RENOVATION
ORGANIZATION COMPANY; a.k.a. IRAN DEVELOPMENT AND RENOVATION ORGANIZATION COMPANY; a.k.a. SAWZEMANE GOSTARESH VA
NOWSAZI SANAYE IRAN), Vali Asr Building, Jam e Jam Street, Vali Asr Avenue, Tehran 15815-3377, Iran; Additional Sanctions Information - Not on
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 46/83
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
SAWZEMANE GOSTARESH VA NOWSAZI SANAYE IRAN (a.k.a. IDRO; a.k.a. INDUSTRIAL DEVELOPMENT AND RENOVATION ORGANIZATION
OF IRAN; a.k.a. IRAN DEVELOPMENT & RENOVATION ORGANIZATION COMPANY; a.k.a. IRAN DEVELOPMENT AND RENOVATION
ORGANIZATION COMPANY), Vali Asr Building, Jam e Jam Street, Vali Asr Avenue, Tehran 15815-3377, Iran; Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
IRAN DEVELOPMENT AND RENOVATION ORGANIZATION COMPANY (a.k.a. IDRO; a.k.a. INDUSTRIAL DEVELOPMENT AND RENOVATION
ORGANIZATION OF IRAN; a.k.a. IRAN DEVELOPMENT & RENOVATION ORGANIZATION COMPANY; a.k.a. SAWZEMANE GOSTARESH VA
NOWSAZI SANAYE IRAN), Vali Asr Building, Jam e Jam Street, Vali Asr Avenue, Tehran 15815-3377, Iran; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
MACHINE SAZI ARAK CO. LTD. (a.k.a. MACHINE SAZI ARAK COMPANY P J S C; a.k.a. MACHINE SAZI ARAK SSA; a.k.a. MASHIN SAZI ARAK;
a.k.a. "MSA"), P.O. Box 148, Arak 351138, Iran; Arak, Km 4 Tehran Road, Arak, Markazi Province, Iran; No. 1, Northern Kargar Street, Tehran 14136,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
"MSA" (a.k.a. MACHINE SAZI ARAK CO. LTD.; a.k.a. MACHINE SAZI ARAK COMPANY P J S C; a.k.a. MACHINE SAZI ARAK SSA; a.k.a. MASHIN
SAZI ARAK), P.O. Box 148, Arak 351138, Iran; Arak, Km 4 Tehran Road, Arak, Markazi Province, Iran; No. 1, Northern Kargar Street, Tehran 14136,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
MASHIN SAZI ARAK (a.k.a. MACHINE SAZI ARAK CO. LTD.; a.k.a. MACHINE SAZI ARAK COMPANY P J S C; a.k.a. MACHINE SAZI ARAK SSA;
a.k.a. "MSA"), P.O. Box 148, Arak 351138, Iran; Arak, Km 4 Tehran Road, Arak, Markazi Province, Iran; No. 1, Northern Kargar Street, Tehran 14136,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
MACHINE SAZI ARAK SSA (a.k.a. MACHINE SAZI ARAK CO. LTD.; a.k.a. MACHINE SAZI ARAK COMPANY P J S C; a.k.a. MASHIN SAZI ARAK;
a.k.a. "MSA"), P.O. Box 148, Arak 351138, Iran; Arak, Km 4 Tehran Road, Arak, Markazi Province, Iran; No. 1, Northern Kargar Street, Tehran 14136,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
MACHINE SAZI ARAK COMPANY P J S C (a.k.a. MACHINE SAZI ARAK CO. LTD.; a.k.a. MACHINE SAZI ARAK SSA; a.k.a. MASHIN SAZI ARAK;
a.k.a. "MSA"), P.O. Box 148, Arak 351138, Iran; Arak, Km 4 Tehran Road, Arak, Markazi Province, Iran; No. 1, Northern Kargar Street, Tehran 14136,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
WEST SUN TRADE GMBH (a.k.a. WEST SUN TRADE), Winterhuder Weg 8, Hamburg 22085, Germany; Arak Machine Mfg. Bldg., 2nd Floor, opp. of
College Economy, Northern Kargar Ave., Tehran 14136, Iran; Mundsburger Damm 16, Hamburg 22087, Germany; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB 45757 (Germany); all offices worldwide [IRAN].
WEST SUN TRADE (a.k.a. WEST SUN TRADE GMBH), Winterhuder Weg 8, Hamburg 22085, Germany; Arak Machine Mfg. Bldg., 2nd Floor, opp. of
College Economy, Northern Kargar Ave., Tehran 14136, Iran; Mundsburger Damm 16, Hamburg 22087, Germany; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID HRB 45757 (Germany); all offices worldwide [IRAN].
POST BANK OF IRAN (a.k.a. SHERKAT-E DOLATI-E POST BANK; a.k.a. "PBI"), 237 Motahari Avenue, Tehran 1587618118, Iran; Motahari Street, No.
237, Past Darya-e Noor, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SHERKAT-E DOLATI-E POST BANK (a.k.a. POST BANK OF IRAN; a.k.a. "PBI"), 237 Motahari Avenue, Tehran 1587618118, Iran; Motahari Street, No.
237, Past Darya-e Noor, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
"PBI" (a.k.a. POST BANK OF IRAN; a.k.a. SHERKAT-E DOLATI-E POST BANK), 237 Motahari Avenue, Tehran 1587618118, Iran; Motahari Street, No.
237, Past Darya-e Noor, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 47/83
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
ONERBANK ZAO (a.k.a. EFTEKHAR BANK; a.k.a. HONOR BANK; a.k.a. HONORBANK; a.k.a. HONORBANK ZAO; a.k.a. ONER BANK; a.k.a.
ONERBANK; a.k.a. ONER-BANK), Ulitsa Klary Tsetkin 51, Minsk 220004, Belarus; SWIFT/BIC HNRBBY2X; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 807000227 (Belarus) issued 16 Oct 2009; all offices worldwide [IRAN].
ONER-BANK (a.k.a. EFTEKHAR BANK; a.k.a. HONOR BANK; a.k.a. HONORBANK; a.k.a. HONORBANK ZAO; a.k.a. ONER BANK; a.k.a.
ONERBANK; a.k.a. ONERBANK ZAO), Ulitsa Klary Tsetkin 51, Minsk 220004, Belarus; SWIFT/BIC HNRBBY2X; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 807000227 (Belarus) issued 16 Oct 2009; all offices worldwide [IRAN].
HONORBANK (a.k.a. EFTEKHAR BANK; a.k.a. HONOR BANK; a.k.a. HONORBANK ZAO; a.k.a. ONER BANK; a.k.a. ONERBANK; a.k.a. ONERBANK;
a.k.a. ONERBANK ZAO), Ulitsa Klary Tsetkin 51, Minsk 220004, Belarus; SWIFT/BIC HNRBBY2X; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 807000227 (Belarus) issued 16 Oct 2009; all offices worldwide [IRAN].
ONERBANK (a.k.a. EFTEKHAR BANK; a.k.a. HONOR BANK; a.k.a. HONORBANK; a.k.a. HONORBANK ZAO; a.k.a. ONER BANK; a.k.a. ONERBANK;
a.k.a. ONERBANK ZAO), Ulitsa Klary Tsetkin 51, Minsk 220004, Belarus; SWIFT/BIC HNRBBY2X; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 807000227 (Belarus) issued 16 Oct 2009; all offices worldwide [IRAN].
EFTEKHAR BANK (a.k.a. HONOR BANK; a.k.a. HONORBANK; a.k.a. HONORBANK ZAO; a.k.a. ONER BANK; a.k.a. ONERBANK; a.k.a. ONERBANK;
a.k.a. ONERBANK ZAO), Ulitsa Klary Tsetkin 51, Minsk 220004, Belarus; SWIFT/BIC HNRBBY2X; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 807000227 (Belarus) issued 16 Oct 2009; all offices worldwide [IRAN].
HONORBANK ZAO (a.k.a. EFTEKHAR BANK; a.k.a. HONOR BANK; a.k.a. HONORBANK; a.k.a. ONER BANK; a.k.a. ONERBANK; a.k.a. ONERBANK;
a.k.a. ONERBANK ZAO), Ulitsa Klary Tsetkin 51, Minsk 220004, Belarus; SWIFT/BIC HNRBBY2X; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 807000227 (Belarus) issued 16 Oct 2009; all offices worldwide [IRAN].
HONOR BANK (a.k.a. EFTEKHAR BANK; a.k.a. HONORBANK; a.k.a. HONORBANK ZAO; a.k.a. ONER BANK; a.k.a. ONERBANK; a.k.a. ONERBANK;
a.k.a. ONERBANK ZAO), Ulitsa Klary Tsetkin 51, Minsk 220004, Belarus; SWIFT/BIC HNRBBY2X; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 807000227 (Belarus) issued 16 Oct 2009; all offices worldwide [IRAN].
ONER BANK (a.k.a. EFTEKHAR BANK; a.k.a. HONOR BANK; a.k.a. HONORBANK; a.k.a. HONORBANK ZAO; a.k.a. ONERBANK; a.k.a. ONERBANK;
a.k.a. ONERBANK ZAO), Ulitsa Klary Tsetkin 51, Minsk 220004, Belarus; SWIFT/BIC HNRBBY2X; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 807000227 (Belarus) issued 16 Oct 2009; all offices worldwide [IRAN].
MSP KALA NAFT CO. TEHRAN (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT
TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT;
a.k.a. MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND
PROCUREMENT KALA NAFT COMPANY; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT
COMPANY; a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN;
a.k.a. SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner
Kalantari Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod
Gharani Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue,
Tehran, Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab
Emirates; 333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie
Chao Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA
NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT AND
PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY; a.k.a.
MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY; a.k.a.
SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a. SHERKATE
POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari Street, 8th
Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani Avenue,
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 48/83
Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran, Iran; Head
Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates; 333 7th Ave
SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao Yang District ,
Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
M.S.P.-KALA (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN COMPANY;
a.k.a. KALAYEH NAFT CO; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING SUPPORT AND
PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY; a.k.a.
MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY; a.k.a.
SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a. SHERKATE
POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari Street, 8th
Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani Avenue,
Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran, Iran; Head
Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates; 333 7th Ave
SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao Yang District ,
Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
KALA NAFT CO SSK (a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN COMPANY; a.k.a. KALAYEH
NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING SUPPORT
AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY;
a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY;
a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a.
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari
Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani
Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran,
Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates;
333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao
Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
KALA NAFT COMPANY LTD (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN COMPANY; a.k.a. KALAYEH
NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING SUPPORT
AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY;
a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY;
a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a.
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari
Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani
Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran,
Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates;
333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao
Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
KALA NAFT TEHRAN (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN COMPANY; a.k.a. KALAYEH
NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING SUPPORT
AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY;
a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY;
a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a.
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari
Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani
Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran,
Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates;
333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao
Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
SHERKAT SAHAMI KHASS KALA NAFT (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA
NAFT TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA
NAFT; a.k.a. MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND
PROCUREMENT KALA NAFT COMPANY; a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP
KALANAFT; a.k.a. MSP-KALANAFT COMPANY; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a.
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 49/83
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari
Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani
Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran,
Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates;
333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao
Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a.
KALA NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING
SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN;
a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY; a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA
NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY; a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a.
SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner
Kalantari Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod
Gharani Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue,
Tehran, Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab
Emirates; 333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie
Chao Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
MSP KALANAFT (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN
COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a.
MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND
PROCUREMENT KALA NAFT COMPANY; a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSPKALANAFT
COMPANY; a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE
NAFT TEHRAN; a.k.a. SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand
Bridge, Corner Kalantari Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street,
Sepahbod Gharani Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani
Avenue, Tehran, Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United
Arab Emirates; 333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao
Waidajie Chao Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; all offices worldwide [IRAN].
KALA NAFT TEHRAN COMPANY (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALAYEH
NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING SUPPORT
AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY;
a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY;
a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a.
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari
Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani
Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran,
Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates;
333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao
Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD;
a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING
SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN;
a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY; a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA
NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY; a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a.
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari
Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani
Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran,
Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates;
333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao
Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
KALAYEH NAFT CO (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN
COMPANY; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING SUPPORT
AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY;
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 50/83
a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY;
a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a.
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari
Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani
Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran,
Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates;
333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao
Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT
COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a.
MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT
COMPANY; a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT
COMPANY; a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN;
a.k.a. SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner
Kalantari Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod
Gharani Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue,
Tehran, Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab
Emirates; 333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie
Chao Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
MSP KALA NAFT TEHRAN COMPANY (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA
NAFT TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA
NAFT; a.k.a. MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND
PROCUREMENT KALA NAFT COMPANY; a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY; a.k.a.
SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a. SHERKATE
POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari Street, 8th
Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani Avenue,
Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran, Iran; Head
Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates; 333 7th Ave
SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao Yang District ,
Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
MANUFACTURING, SUPPORT AND PROCUREMENT KALA NAFT COMPANY (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD;
a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING
SUPPORT & PROCUREMENT CO.-KALA NAFT; a.k.a. MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN;
a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP KALANAFT; a.k.a. MSP-KALANAFT COMPANY;
a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN; a.k.a.
SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner Kalantari
Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod Gharani
Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue, Tehran,
Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab Emirates;
333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie Chao
Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
MSP-KALANAFT COMPANY (a.k.a. KALA NAFT CO SSK; a.k.a. KALA NAFT COMPANY LTD; a.k.a. KALA NAFT TEHRAN; a.k.a. KALA NAFT
TEHRAN COMPANY; a.k.a. KALAYEH NAFT CO; a.k.a. M.S.P.-KALA; a.k.a. MANUFACTURING SUPPORT & PROCUREMENT CO.-KALA NAFT;
a.k.a. MANUFACTURING SUPPORT AND PROCUREMENT (M.S.P.) KALA NAFT CO. TEHRAN; a.k.a. MANUFACTURING, SUPPORT AND
PROCUREMENT KALA NAFT COMPANY; a.k.a. MSP KALA NAFT CO. TEHRAN; a.k.a. MSP KALA NAFT TEHRAN COMPANY; a.k.a. MSP
KALANAFT; a.k.a. SHERKAT SAHAMI KHASS KALA NAFT; a.k.a. SHERKAT SAHAMI KHASS POSHTIBANI VA TEHIYEH KALAYE NAFT TEHRAN;
a.k.a. SHERKATE POSHTIBANI SAKHT VA TAHEIH KALAIE NAFTE TEHRAN), 242 Sepahbod Gharani Street, Karim Khan Zand Bridge, Corner
Kalantari Street, 8th Floor, P.O. Box 15815-1775/15815-3446, Tehran 15988, Iran; Building No. 226, Corner of Shahid Kalantari Street, Sepahbod
Gharani Avenue, Karimkhan Avenue, Tehran 1598844815, Iran; No. 242, Shahid Kalantari St., Near Karimkhan Bridge, Sepahbod Gharani Avenue,
Tehran, Iran; Head Office Tehran, Sepahbod Gharani Ave., P.O. Box 15815/1775 15815/3446, Tehran, Iran; P.O. Box 2965, Sharjah, United Arab
Emirates; 333 7th Ave SW #1102, Calgary, AB T2P 2Z1, Canada; Chekhov St., 24.2 , AP 57, Moscow, Russia; Room No. 704 - No. 10 Chao Waidajie
Chao Yang District , Beijing 10020, China; Sanaee Ave., P.O. Box 79417-76349, N.I.O.C., Kish, Iran; 10th Floor, Sadaf Tower, Kish Island, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; all offices worldwide [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 51/83
MAHAB GHODSS CONSULTING ENGINEERING COMPANY (a.k.a. MAHAB GHODSS CONSULTING ENGINEERING CO.; a.k.a. MAHAB GHODSS
CONSULTING ENGINEERS SSK; a.k.a. MAHAB QODS ENGINEERING CONSULTING CO.), No. 17, Dastgerdy Avenue, Takharestan Alley, 19395-
6875, Tehran 1918781185, Iran; 16 Takharestan Alley, Dastgerdy Avenue, P.O. Box 19395-6875, Tehran 19187 81185, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 48962 (Iran) issued 1983; all offices worldwide [IRAN].
MAHAB GHODSS CONSULTING ENGINEERS SSK (a.k.a. MAHAB GHODSS CONSULTING ENGINEERING CO.; a.k.a. MAHAB GHODSS
CONSULTING ENGINEERING COMPANY; a.k.a. MAHAB QODS ENGINEERING CONSULTING CO.), No. 17, Dastgerdy Avenue, Takharestan Alley,
19395-6875, Tehran 1918781185, Iran; 16 Takharestan Alley, Dastgerdy Avenue, P.O. Box 19395-6875, Tehran 19187 81185, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 48962 (Iran) issued 1983; all offices worldwide [IRAN].
MAHAB GHODSS CONSULTING ENGINEERING CO. (a.k.a. MAHAB GHODSS CONSULTING ENGINEERING COMPANY; a.k.a. MAHAB GHODSS
CONSULTING ENGINEERS SSK; a.k.a. MAHAB QODS ENGINEERING CONSULTING CO.), No. 17, Dastgerdy Avenue, Takharestan Alley, 19395-
6875, Tehran 1918781185, Iran; 16 Takharestan Alley, Dastgerdy Avenue, P.O. Box 19395-6875, Tehran 19187 81185, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 48962 (Iran) issued 1983; all offices worldwide [IRAN].
MAHAB QODS ENGINEERING CONSULTING CO. (a.k.a. MAHAB GHODSS CONSULTING ENGINEERING CO.; a.k.a. MAHAB GHODSS
CONSULTING ENGINEERING COMPANY; a.k.a. MAHAB GHODSS CONSULTING ENGINEERS SSK), No. 17, Dastgerdy Avenue, Takharestan
Alley, 19395-6875, Tehran 1918781185, Iran; 16 Takharestan Alley, Dastgerdy Avenue, P.O. Box 19395-6875, Tehran 19187 81185, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 48962 (Iran) issued 1983; all offices worldwide [IRAN].
PARS OIL AND GAS COMPANY (a.k.a. POGC), No. 133, Side of Parvin Etesami Alley, opposite Sazman Ab - Dr. Fatemi Avenue, Tehran, Iran; No. 1
Parvin Etesami Street, Fatemi Avenue, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions;
U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
POGC (a.k.a. PARS OIL AND GAS COMPANY), No. 133, Side of Parvin Etesami Alley, opposite Sazman Ab - Dr. Fatemi Avenue, Tehran, Iran; No. 1
Parvin Etesami Street, Fatemi Avenue, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions;
U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
EGHTESAD NOVIN BANK (a.k.a. BANK-E EGHTESAD NOVIN; a.k.a. EN BANK PJSC), Vali Asr Street, Above Vanak Circle, across Niayesh,
Esfandiari Blvd., No. 24, Tehran, Iran; SWIFT/BIC BEGNIRTH; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BANK-E EGHTESAD NOVIN (a.k.a. EGHTESAD NOVIN BANK; a.k.a. EN BANK PJSC), Vali Asr Street, Above Vanak Circle, across Niayesh,
Esfandiari Blvd., No. 24, Tehran, Iran; SWIFT/BIC BEGNIRTH; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
EN BANK PJSC (a.k.a. BANK-E EGHTESAD NOVIN; a.k.a. EGHTESAD NOVIN BANK), Vali Asr Street, Above Vanak Circle, across Niayesh,
Esfandiari Blvd., No. 24, Tehran, Iran; SWIFT/BIC BEGNIRTH; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
PASARGAD BANK (a.k.a. BANK-E PASARGAD), Valiasr St., Mirdamad St., No. 430, Tehran, Iran; SWIFT/BIC BKBPIRTH; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BANK-E PASARGAD (a.k.a. PASARGAD BANK), Valiasr St., Mirdamad St., No. 430, Tehran, Iran; SWIFT/BIC BKBPIRTH; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
KARAFARIN BANK (a.k.a. BANK-E KARAFARIN), Zafar St. No. 315, Between Vali Asr and Jordan, Tehran, Iran; SWIFT/BIC KBIDIRTH; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BANK-E KARAFARIN (a.k.a. KARAFARIN BANK), Zafar St. No. 315, Between Vali Asr and Jordan, Tehran, Iran; SWIFT/BIC KBIDIRTH; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 52/83
SAMAN BANK (a.k.a. BANK-E SAMAN), Vali Asr. St. No. 3, Before Vey Park intersection, corner of Tarakesh Dooz St. , Tehran, Iran; SWIFT/BIC
SABCIRTH; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BANK-E SAMAN (a.k.a. SAMAN BANK), Vali Asr. St. No. 3, Before Vey Park intersection, corner of Tarakesh Dooz St. , Tehran, Iran; SWIFT/BIC
SABCIRTH; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SARMAYEH BANK (a.k.a. BANK-E SARMAYEH), Sepahod Gharani No. 24, Corner of Arak St., Tehran, Iran; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BANK-E SARMAYEH (a.k.a. SARMAYEH BANK), Sepahod Gharani No. 24, Corner of Arak St., Tehran, Iran; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
TAT BANK (a.k.a. BANK-E TAT), Shahid Ahmad Ghasir (Bocharest), Shahid Ahmadian (15th) St., No. 1, Tehran, Iran; No. 1 Ahmadian Street,
Bokharest Avenue, Tehran, Iran; SWIFT/BIC TATBIRTH; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BANK-E TAT (a.k.a. TAT BANK), Shahid Ahmad Ghasir (Bocharest), Shahid Ahmadian (15th) St., No. 1, Tehran, Iran; No. 1 Ahmadian Street,
Bokharest Avenue, Tehran, Iran; SWIFT/BIC TATBIRTH; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BANK-E SHAHR, Sepahod Gharani, Corner of Khosro St., No. 147, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
DEY BANK (a.k.a. BANK-E DEY), Bokharest St., 1st St., No. 13, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order
13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BANK-E DEY (a.k.a. DEY BANK), Bokharest St., 1st St., No. 13, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order
13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
HEKMAT IRANIAN BANK (a.k.a. BANK-E HEKMAT IRANIAN), Argentine Circle, beginning of Africa St., Corner of 37th St., (Dara Cul-de-sac), No.26,
Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block
the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BANK-E HEKMAT IRANIAN (a.k.a. HEKMAT IRANIAN BANK), Argentine Circle, beginning of Africa St., Corner of 37th St., (Dara Cul-de-sac), No.26,
Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block
the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TOURISM BANK (a.k.a. BANK-E GARDESHGARI), Vali Asr St., above Vey Park, Shahid Fiazi St., No. 51, first floor, Tehran, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BANK-E GARDESHGARI (a.k.a. TOURISM BANK), Vali Asr St., above Vey Park, Shahid Fiazi St., No. 51, first floor, Tehran, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
IRAN ZAMIN BANK (a.k.a. BANK-E IRAN ZAMIN), Seyyed Jamal-oldin Asadabadi St., Corner of 68th St., No. 472, Tehran, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BANK-E IRAN ZAMIN (a.k.a. IRAN ZAMIN BANK), Seyyed Jamal-oldin Asadabadi St., Corner of 68th St., No. 472, Tehran, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 53/83
MEHR IRAN CREDIT UNION BANK (a.k.a. BANK-E GHARZOLHASANEH MEHR IRAN; a.k.a. GHARZOLHASANEH MEHR IRAN BANK), Taleghani
St., No.204, Before the intersection of Mofateh, across from the former U.S. embassy, Tehran, Iran; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
BANK-E GHARZOLHASANEH MEHR IRAN (a.k.a. GHARZOLHASANEH MEHR IRAN BANK; a.k.a. MEHR IRAN CREDIT UNION BANK), Taleghani
St., No.204, Before the intersection of Mofateh, across from the former U.S. embassy, Tehran, Iran; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
GHARZOLHASANEH MEHR IRAN BANK (a.k.a. BANK-E GHARZOLHASANEH MEHR IRAN; a.k.a. MEHR IRAN CREDIT UNION BANK), Taleghani
St., No.204, Before the intersection of Mofateh, across from the former U.S. embassy, Tehran, Iran; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
JOINT IRAN-VENEZUELA BANK (a.k.a. BANK MOSHTAREK-E IRAN VENEZUELA; a.k.a. IRANIAN-VENEZUELAN BI-NATIONAL BANK), Ahmad
Ghasir St. (Bokharest), Corner of 15th St., Tose Tower, No.44-46, Tehran 1013830711, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
BANK MOSHTAREK-E IRAN VENEZUELA (a.k.a. IRANIAN-VENEZUELAN BI-NATIONAL BANK; a.k.a. JOINT IRAN-VENEZUELA BANK), Ahmad
Ghasir St. (Bokharest), Corner of 15th St., Tose Tower, No.44-46, Tehran 1013830711, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
IRANIAN-VENEZUELAN BI-NATIONAL BANK (a.k.a. BANK MOSHTAREK-E IRAN VENEZUELA; a.k.a. JOINT IRAN-VENEZUELA BANK), Ahmad
Ghasir St. (Bokharest), Corner of 15th St., Tose Tower, No.44-46, Tehran 1013830711, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
TOSEE TAAVON BANK (a.k.a. BANK-E TOSE'E TA'AVON; a.k.a. COOPERATIVE DEVELOPMENT BANK), Mirdamad Blvd., North East Corner of
Mirdamad Bridge, No. 271, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BANK-E TOSE'E TA'AVON (a.k.a. COOPERATIVE DEVELOPMENT BANK; a.k.a. TOSEE TAAVON BANK), Mirdamad Blvd., North East Corner of
Mirdamad Bridge, No. 271, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
COOPERATIVE DEVELOPMENT BANK (a.k.a. BANK-E TOSE'E TA'AVON; a.k.a. TOSEE TAAVON BANK), Mirdamad Blvd., North East Corner of
Mirdamad Bridge, No. 271, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
ISLAMIC REGIONAL COOPERATION BANK (a.k.a. BANK-E TAAWON MANTAGHEEY-E ESLAMI; a.k.a. REGIONAL COOPERATION OF THE
ISLAMIC BANK FOR DEVELOPMENT & INVESTMENT), Building No. 59, District 929, Street No. 17, Arsat Al-Hindia, Al Masbah, Baghdad, Iraq;
Tohid Street, Before Tohid Circle, No. 33, Upper Level of Eghtesad-e Novin Bank, Tehran 1419913464, Iran; SWIFT/BIC RCDFIQBA; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BANK-E TAAWON MANTAGHEEY-E ESLAMI (a.k.a. ISLAMIC REGIONAL COOPERATION BANK; a.k.a. REGIONAL COOPERATION OF THE
ISLAMIC BANK FOR DEVELOPMENT & INVESTMENT), Building No. 59, District 929, Street No. 17, Arsat Al-Hindia, Al Masbah, Baghdad, Iraq;
Tohid Street, Before Tohid Circle, No. 33, Upper Level of Eghtesad-e Novin Bank, Tehran 1419913464, Iran; SWIFT/BIC RCDFIQBA; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
REGIONAL COOPERATION OF THE ISLAMIC BANK FOR DEVELOPMENT & INVESTMENT (a.k.a. BANK-E TAAWON MANTAGHEEY-E ESLAMI;
a.k.a. ISLAMIC REGIONAL COOPERATION BANK), Building No. 59, District 929, Street No. 17, Arsat Al-Hindia, Al Masbah, Baghdad, Iraq; Tohid
Street, Before Tohid Circle, No. 33, Upper Level of Eghtesad-e Novin Bank, Tehran 1419913464, Iran; SWIFT/BIC RCDFIQBA; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 54/83
CREDIT INSTITUTION FOR DEVELOPMENT, 53 Saanee, Jahan-e Koodak, Crossroads Africa St., Tehran, Iran; Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SHONA (f.k.a. ABADAN; f.k.a. ALPHA) (T2EU4) Crude/Oil Products Tanker 99,144DWT 56,068GRT Tanzania flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9187629; MMSI 572469210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ABADAN (f.k.a. ALPHA; a.k.a. SHONA) (T2EU4) Crude/Oil Products Tanker 99,144DWT 56,068GRT Tanzania flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9187629; MMSI 572469210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ALPHA (f.k.a. ABADAN; a.k.a. SHONA) (T2EU4) Crude/Oil Products Tanker 99,144DWT 56,068GRT Tanzania flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9187629; MMSI 572469210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SUNDIAL (f.k.a. ABADEH; f.k.a. CRYSTAL) (9HDQ9) Crude/Oil Products Tanker 99,030DWT 56,068GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9187655; MMSI
256842000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ABADEH (f.k.a. CRYSTAL; a.k.a. SUNDIAL) (9HDQ9) Crude/Oil Products Tanker 99,030DWT 56,068GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9187655; MMSI
256842000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
CRYSTAL (f.k.a. ABADEH; a.k.a. SUNDIAL) (9HDQ9) Crude/Oil Products Tanker 99,030DWT 56,068GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9187655; MMSI
256842000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SILVER CLOUD (f.k.a. AMOL; f.k.a. CASTOR; f.k.a. CHRISTINA) (T2EM4) Crude/Oil Products Tanker 99,094DWT 56,068GRT None Identified flag;
Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9187667; MMSI 256843000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
AMOL (f.k.a. CASTOR; f.k.a. CHRISTINA; a.k.a. SILVER CLOUD) (T2EM4) Crude/Oil Products Tanker 99,094DWT 56,068GRT None Identified flag;
Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9187667; MMSI 256843000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
CASTOR (f.k.a. AMOL; f.k.a. CHRISTINA; a.k.a. SILVER CLOUD) (T2EM4) Crude/Oil Products Tanker 99,094DWT 56,068GRT None Identified flag;
Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9187667; MMSI 256843000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
CHRISTINA (f.k.a. AMOL; f.k.a. CASTOR; a.k.a. SILVER CLOUD) (T2EM4) Crude/Oil Products Tanker 99,094DWT 56,068GRT None Identified flag;
Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9187667; MMSI 256843000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ALERT (f.k.a. ASTANEH; f.k.a. NEPTUNE; f.k.a. SEAPRIDE) (T2ES4) Crude/Oil Products Tanker 99,144DWT 56,068GRT None Identified flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9187643; MMSI 572467210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ASTANEH (a.k.a. ALERT; f.k.a. NEPTUNE; f.k.a. SEAPRIDE) (T2ES4) Crude/Oil Products Tanker 99,144DWT 56,068GRT None Identified flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 55/83
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9187643; MMSI 572467210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NEPTUNE (a.k.a. ALERT; f.k.a. ASTANEH; f.k.a. SEAPRIDE) (T2ES4) Crude/Oil Products Tanker 99,144DWT 56,068GRT None Identified flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9187643; MMSI 572467210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SEAPRIDE (a.k.a. ALERT; f.k.a. ASTANEH; f.k.a. NEPTUNE) (T2ES4) Crude/Oil Products Tanker 99,144DWT 56,068GRT None Identified flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9187643; MMSI 572467210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ABELIA (f.k.a. ASTARA; f.k.a. JUPITER) (9HDS9) Crude/Oil Products Tanker 99,087DWT 56,068GRT None Identified flag; Former Vessel Flag Tuvalu;
alt. Former Vessel Flag Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9187631; MMSI
256845000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ASTARA (a.k.a. ABELIA; f.k.a. JUPITER) (9HDS9) Crude/Oil Products Tanker 99,087DWT 56,068GRT None Identified flag; Former Vessel Flag
Tuvalu; alt. Former Vessel Flag Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9187631; MMSI
256845000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
JUPITER (a.k.a. ABELIA; f.k.a. ASTARA) (9HDS9) Crude/Oil Products Tanker 99,087DWT 56,068GRT None Identified flag; Former Vessel Flag
Tuvalu; alt. Former Vessel Flag Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9187631; MMSI
256845000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BANEH (EQKF) Landing Craft 640DWT 478GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 8508462;
MMSI 422141000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DAMAVAND (9HEG9) Crude Oil Tanker 297,013DWT 160,576GRT None Identified flag; Former Vessel Flag Malta; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9218478; MMSI 256865000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
DECESIVE (f.k.a. DANESH; f.k.a. LEADERSHIP) (5IM 592) Crude Oil Tanker 319,988DWT 164,241GRT None Identified flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9356593; MMSI
677049200 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DANESH (a.k.a. DECESIVE; f.k.a. LEADERSHIP) (5IM 592) Crude Oil Tanker 319,988DWT 164,241GRT None Identified flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9356593; MMSI
677049200 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
LEADERSHIP (f.k.a. DANESH; a.k.a. DECESIVE) (5IM 592) Crude Oil Tanker 319,988DWT 164,241GRT None Identified flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9356593; MMSI
677049200 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DARAB (9HEE9) Crude Oil Tanker 296,803DWT 160,576GRT None Identified flag; Former Vessel Flag Malta; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9218492; MMSI 256862000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DAL LAKE (f.k.a. COMPANION; f.k.a. DAVAR) (5IM 593) Crude Oil Tanker 317,850DWT 164,241GRT None Identified flag; Former Vessel Flag Cyprus;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357717; MMSI
677049300 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 56/83
DAVAR (f.k.a. COMPANION; a.k.a. DAL LAKE) (5IM 593) Crude Oil Tanker 317,850DWT 164,241GRT None Identified flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357717; MMSI
677049300 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
COMPANION (a.k.a. DAL LAKE; f.k.a. DAVAR) (5IM 593) Crude Oil Tanker 317,850DWT 164,241GRT None Identified flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357717; MMSI
677049300 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DAYLAM (9HEU9) Crude Oil Tanker 299,500DWT 160,576GRT None Identified flag; Former Vessel Flag Malta; Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9218466; MMSI 256872000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DELVAR (9HEF9) Crude Oil Tanker 299,500DWT 160,576GRT None Identified flag; Former Vessel Flag Malta; Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9218454; MMSI 256864000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DENA (9HED9) Crude Oil Tanker 296,894DWT 160,576GRT None Identified flag; Former Vessel Flag Malta; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9218480; MMSI 256861000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
FIANGA (f.k.a. FAEZ; f.k.a. MAESTRO; f.k.a. SATEEN) (T2DM4) Chemical/Products Tanker 35,124DWT 25,214GRT None Identified flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9283760; MMSI 572438210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
FAEZ (a.k.a. FIANGA; f.k.a. MAESTRO; f.k.a. SATEEN) (T2DM4) Chemical/Products Tanker 35,124DWT 25,214GRT None Identified flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9283760; MMSI 572438210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SATEEN (f.k.a. FAEZ; a.k.a. FIANGA; f.k.a. MAESTRO) (T2DM4) Chemical/Products Tanker 35,124DWT 25,214GRT None Identified flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9283760; MMSI 572438210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MAESTRO (f.k.a. FAEZ; a.k.a. FIANGA; f.k.a. SATEEN) (T2DM4) Chemical/Products Tanker 35,124DWT 25,214GRT None Identified flag; Former
Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9283760; MMSI 572438210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ZEUS (f.k.a. HADI; f.k.a. PIONEER) (T2EJ4) Crude Oil Tanker 317,355DWT 163,650GRT None Identified flag; Former Vessel Flag Cyprus; alt. Former
Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9362073; MMSI
572459210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HADI (f.k.a. PIONEER; a.k.a. ZEUS) (T2EJ4) Crude Oil Tanker 317,355DWT 163,650GRT None Identified flag; Former Vessel Flag Cyprus; alt. Former
Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9362073; MMSI
572459210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
PIONEER (f.k.a. HADI; a.k.a. ZEUS) (T2EJ4) Crude Oil Tanker 317,355DWT 163,650GRT None Identified flag; Former Vessel Flag Cyprus; alt. Former
Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9362073; MMSI
572459210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HALISTIC (f.k.a. HAMOON; f.k.a. LENA; f.k.a. TAMAR) (T2EQ4) Crude Oil Tanker 299,242DWT 160,930GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 57/83
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9212929; MMSI 572465210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HAMOON (a.k.a. HALISTIC; f.k.a. LENA; f.k.a. TAMAR) (T2EQ4) Crude Oil Tanker 299,242DWT 160,930GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9212929; MMSI 572465210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
LENA (a.k.a. HALISTIC; f.k.a. HAMOON; f.k.a. TAMAR) (T2EQ4) Crude Oil Tanker 299,242DWT 160,930GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9212929; MMSI 572465210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
TAMAR (a.k.a. HALISTIC; f.k.a. HAMOON; f.k.a. LENA) (T2EQ4) Crude Oil Tanker 299,242DWT 160,930GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9212929; MMSI 572465210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
AMBER (f.k.a. FREEDOM; f.k.a. HARAZ) (5IM 597) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former Vessel Flag Cyprus; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357406; MMSI
677049700 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HARAZ (a.k.a. AMBER; f.k.a. FREEDOM) (5IM 597) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former Vessel Flag Cyprus; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357406; MMSI
677049700 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
FREEDOM (a.k.a. AMBER; f.k.a. HARAZ) (5IM 597) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former Vessel Flag Cyprus; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357406; MMSI
677049700 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MARINA (f.k.a. HARSIN; f.k.a. VALOR) (5IM600) Crude Oil Tanker 299,229DWT 160,930GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9212917; MMSI
677050000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HARSIN (a.k.a. MARINA; f.k.a. VALOR) (5IM600) Crude Oil Tanker 299,229DWT 160,930GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9212917; MMSI
677050000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
VALOR (f.k.a. HARSIN; a.k.a. MARINA) (5IM600) Crude Oil Tanker 299,229DWT 160,930GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9212917; MMSI
677050000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MAJESTIC (f.k.a. GLORY; f.k.a. HATEF) (T2EG4) Crude Oil Tanker 317,367DWT 163,660GRT Tanzania flag; Former Vessel Flag Cyprus; alt. Former
Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357183; MMSI
212256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HATEF (f.k.a. GLORY; a.k.a. MAJESTIC) (T2EG4) Crude Oil Tanker 317,367DWT 163,660GRT Tanzania flag; Former Vessel Flag Cyprus; alt. Former
Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357183; MMSI
212256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
GLORY (f.k.a. HATEF; a.k.a. MAJESTIC) (T2EG4) Crude Oil Tanker 317,367DWT 163,660GRT Tanzania flag; Former Vessel Flag Cyprus; alt. Former
Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 58/83
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357183; MMSI
212256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HAPPINESS (f.k.a. HENGAM; f.k.a. LOYAL; f.k.a. TULAR) (T2ER4) Crude Oil Tanker 299,214DWT 160,930GRT None Identified flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9212905; MMSI 256875000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HENGAM (a.k.a. HAPPINESS; f.k.a. LOYAL; f.k.a. TULAR) (T2ER4) Crude Oil Tanker 299,214DWT 160,930GRT None Identified flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9212905; MMSI 256875000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
LOYAL (a.k.a. HAPPINESS; f.k.a. HENGAM; f.k.a. TULAR) (T2ER4) Crude Oil Tanker 299,214DWT 160,930GRT None Identified flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9212905; MMSI 256875000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
TULAR (a.k.a. HAPPINESS; f.k.a. HENGAM; f.k.a. LOYAL) (T2ER4) Crude Oil Tanker 299,214DWT 160,930GRT None Identified flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9212905; MMSI 256875000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HONESTY (f.k.a. HIRMAND; f.k.a. HONESTY; f.k.a. MILLIONAIRE) (T2DZ4) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former
Vessel Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9357391; MMSI 572450210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HIRMAND (a.k.a. HONESTY; f.k.a. HONESTY; f.k.a. MILLIONAIRE) (T2DZ4) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former
Vessel Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9357391; MMSI 572450210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HONESTY (f.k.a. HIRMAND; a.k.a. HONESTY; f.k.a. MILLIONAIRE) (T2DZ4) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former
Vessel Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9357391; MMSI 572450210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MILLIONAIRE (f.k.a. HIRMAND; a.k.a. HONESTY; f.k.a. HONESTY) (T2DZ4) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former
Vessel Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9357391; MMSI 572450210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HYDRA (f.k.a. EXPLORER; f.k.a. HODA; f.k.a. PRECIOUS) (T2EH4) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former Vessel
Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9362059; MMSI 572458210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HODA (f.k.a. EXPLORER; a.k.a. HYDRA; f.k.a. PRECIOUS) (T2EH4) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former Vessel
Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9362059; MMSI 572458210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
PRECIOUS (f.k.a. EXPLORER; f.k.a. HODA; a.k.a. HYDRA) (T2EH4) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former Vessel
Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9362059; MMSI 572458210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
EXPLORER (f.k.a. HODA; a.k.a. HYDRA; f.k.a. PRECIOUS) (T2EH4) Crude Oil Tanker 317,356DWT 163,660GRT None Identified flag; Former Vessel
Flag Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 59/83
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9362059; MMSI 572458210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
COURAGE (f.k.a. HOMA) (5IM 596) Crude Oil Tanker 317,367DWT 163,660GRT None Identified flag; Former Vessel Flag Cyprus; alt. Former Vessel
Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block
this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9357389; MMSI 677049600 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
HOMA (a.k.a. COURAGE) (5IM 596) Crude Oil Tanker 317,367DWT 163,660GRT None Identified flag; Former Vessel Flag Cyprus; alt. Former Vessel
Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block
this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9357389; MMSI 677049600 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
DOVE (f.k.a. HONAR; f.k.a. JANUS; f.k.a. VICTORY) (T2EA4) Crude Oil Tanker 317,367DWT 163,660GRT None Identified flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9362061; MMSI 209511000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HONAR (a.k.a. DOVE; f.k.a. JANUS; f.k.a. VICTORY) (T2EA4) Crude Oil Tanker 317,367DWT 163,660GRT None Identified flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9362061; MMSI 209511000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
VICTORY (a.k.a. DOVE; f.k.a. HONAR; f.k.a. JANUS) (T2EA4) Crude Oil Tanker 317,367DWT 163,660GRT None Identified flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9362061; MMSI 209511000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
JANUS (a.k.a. DOVE; f.k.a. HONAR; f.k.a. VICTORY) (T2EA4) Crude Oil Tanker 317,367DWT 163,660GRT None Identified flag; Former Vessel Flag
Cyprus; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9362061; MMSI 209511000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HORIZON (f.k.a. HORMOZ; f.k.a. SCORPIAN) (9HEK9) Crude Oil Tanker 299,261DWT 160,930GRT None Identified flag; Former Vessel Flag Tuvalu;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9212890; MMSI
256870000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HORMOZ (a.k.a. HORIZON; f.k.a. SCORPIAN) (9HEK9) Crude Oil Tanker 299,261DWT 160,930GRT None Identified flag; Former Vessel Flag Tuvalu;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9212890; MMSI
256870000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SCORPIAN (a.k.a. HORIZON; f.k.a. HORMOZ) (9HEK9) Crude Oil Tanker 299,261DWT 160,930GRT None Identified flag; Former Vessel Flag Tuvalu;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9212890; MMSI
256870000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
HUWAYZEH (9HEJ9) Crude Oil Tanker 299,242DWT 160,930GRT None Identified flag; Former Vessel Flag Malta; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9212888; MMSI 256869000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
IMICO NEKA 455 (a.k.a. YARD NO. 455 IRAN MARINE) Shuttle Tanker 63,000DWT 40,800GRT Iran flag; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9404546 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YARD NO. 455 IRAN MARINE (a.k.a. IMICO NEKA 455) Shuttle Tanker 63,000DWT 40,800GRT Iran flag; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9404546 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 60/83
IMICO NEKA 456 (a.k.a. YARD NO. 456 IRAN MARINE) Shuttle Tanker 63,000DWT 40,800GRT Iran flag; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9404558 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YARD NO. 456 IRAN MARINE (a.k.a. IMICO NEKA 456) Shuttle Tanker 63,000DWT 40,800GRT Iran flag; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9404558 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
IMICO NEKA 457 (a.k.a. YARD NO. 457 IRAN MARINE) Shuttle Tanker 63,000DWT 40,800GRT Iran flag; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9404560 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YARD NO. 457 IRAN MARINE (a.k.a. IMICO NEKA 457) Shuttle Tanker 63,000DWT 40,800GRT Iran flag; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9404560 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
IRAN FAHIM Chemical/Products Tanker 34,900DWT 26,561GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9286140 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
IRAN FALAGH Chemical/Products Tanker 34,900DWT 25,000GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9286152 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
IRAN FAZEL (9BAC) Chemical/Products Tanker 35,155DWT 25,214GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9283746; MMSI 422303000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MARIVAN (EQKH) Tanker 640DWT 478GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions;
U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please
see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 8517243; MMSI
422143000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NYOS (f.k.a. BRAWNY; f.k.a. MARIGOLD; f.k.a. NABI) (T2DS4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079080; MMSI 572443210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NABI (f.k.a. BRAWNY; f.k.a. MARIGOLD; a.k.a. NYOS) (T2DS4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079080; MMSI 572443210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BRAWNY (f.k.a. MARIGOLD; f.k.a. NABI; a.k.a. NYOS) (T2DS4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079080; MMSI 572443210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MARIGOLD (f.k.a. BRAWNY; f.k.a. NABI; a.k.a. NYOS) (T2DS4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079080; MMSI 572443210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NAINITAL (f.k.a. MIDSEA; f.k.a. MOTION; f.k.a. NAJM) (T2DR4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079092; MMSI 572442210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NAJM (f.k.a. MIDSEA; f.k.a. MOTION; a.k.a. NAINITAL) (T2DR4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 61/83
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079092; MMSI 572442210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MOTION (f.k.a. MIDSEA; a.k.a. NAINITAL; f.k.a. NAJM) (T2DR4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079092; MMSI 572442210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MIDSEA (f.k.a. MOTION; a.k.a. NAINITAL; f.k.a. NAJM) (T2DR4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079092; MMSI 572442210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NATIVE LAND (f.k.a. NESA; f.k.a. OCEANIC; f.k.a. TRUTH) (T2DP4) Crude Oil Tanker 298,732DWT 156,809GRT Tanzania flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9079107; MMSI
572440210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NESA (a.k.a. NATIVE LAND; f.k.a. OCEANIC; f.k.a. TRUTH) (T2DP4) Crude Oil Tanker 298,732DWT 156,809GRT Tanzania flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9079107; MMSI
572440210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
TRUTH (a.k.a. NATIVE LAND; f.k.a. NESA; f.k.a. OCEANIC) (T2DP4) Crude Oil Tanker 298,732DWT 156,809GRT Tanzania flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9079107; MMSI
572440210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
OCEANIC (a.k.a. NATIVE LAND; f.k.a. NESA; f.k.a. TRUTH) (T2DP4) Crude Oil Tanker 298,732DWT 156,809GRT Tanzania flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9079107; MMSI
572440210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NAPOLI (f.k.a. ELITE; f.k.a. NOAH; f.k.a. VOYAGER) (T2DQ4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079078; MMSI 572441210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NOAH (f.k.a. ELITE; a.k.a. NAPOLI; f.k.a. VOYAGER) (T2DQ4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079078; MMSI 572441210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ELITE (a.k.a. NAPOLI; f.k.a. NOAH; f.k.a. VOYAGER) (T2DQ4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079078; MMSI 572441210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
VOYAGER (f.k.a. ELITE; a.k.a. NAPOLI; f.k.a. NOAH) (T2DQ4) Crude Oil Tanker 298,731DWT 156,809GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9079078; MMSI 572441210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MAHARLIKA (f.k.a. NOOR) (9HES9) Crude Oil Tanker 298,732DWT 156,809GRT Tanzania flag; Former Vessel Flag Malta; alt. Former Vessel Flag
Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this
Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9079066; MMSI 256882000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
NOOR (a.k.a. MAHARLIKA) (9HES9) Crude Oil Tanker 298,732DWT 156,809GRT Tanzania flag; Former Vessel Flag Malta; alt. Former Vessel Flag
Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this
Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 62/83
center/sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9079066; MMSI 256882000 (vessel) [IRAN] (Linked To:
NATIONAL IRANIAN TANKER COMPANY).
SUNSHINE (f.k.a. CARNATION; f.k.a. SAFE; a.k.a. YARD NO. 1220 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT None
Identified flag; Former Vessel Flag Tuvalu; alt. Former Vessel Flag Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9569205 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YARD NO. 1220 SHANGHAI WAIGAOQIAO (f.k.a. CARNATION; f.k.a. SAFE; a.k.a. SUNSHINE) Crude Oil Tanker 318,000DWT 165,000GRT None
Identified flag; Former Vessel Flag Tuvalu; alt. Former Vessel Flag Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9569205 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SAFE (f.k.a. CARNATION; a.k.a. SUNSHINE; a.k.a. YARD NO. 1220 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT None
Identified flag; Former Vessel Flag Tuvalu; alt. Former Vessel Flag Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9569205 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
CARNATION (f.k.a. SAFE; a.k.a. SUNSHINE; a.k.a. YARD NO. 1220 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT None
Identified flag; Former Vessel Flag Tuvalu; alt. Former Vessel Flag Malta; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…;
Vessel Registration Identification IMO 9569205 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SPOTLESS (f.k.a. LANTANA; f.k.a. SANANDAJ) (5IM591) Crude Oil Tanker 159,681DWT 81,479GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9172040; MMSI
677049100 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SANANDAJ (f.k.a. LANTANA; a.k.a. SPOTLESS) (5IM591) Crude Oil Tanker 159,681DWT 81,479GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9172040; MMSI
677049100 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
LANTANA (f.k.a. SANANDAJ; a.k.a. SPOTLESS) (5IM591) Crude Oil Tanker 159,681DWT 81,479GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9172040; MMSI
677049100 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SARDASHT (EQKG) Landing Craft 640DWT 478GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 8517231;
MMSI 422142000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SPLENDOUR (f.k.a. BLACKSTONE; f.k.a. SARV) (9HNZ9) Crude Oil Tanker 163,870DWT 85,462GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Seychelles; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9357377; MMSI 249257000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SARV (f.k.a. BLACKSTONE; a.k.a. SPLENDOUR) (9HNZ9) Crude Oil Tanker 163,870DWT 85,462GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Seychelles; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9357377; MMSI 249257000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BLACKSTONE (f.k.a. SARV; a.k.a. SPLENDOUR) (9HNZ9) Crude Oil Tanker 163,870DWT 85,462GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Seychelles; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9357377; MMSI 249257000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SABRINA (f.k.a. MAGNOLIA; f.k.a. SARVESTAN) (5IM590) Crude Oil Tanker 159,711DWT 81,479GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9172052; MMSI
677049000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 63/83
SARVESTAN (f.k.a. MAGNOLIA; a.k.a. SABRINA) (5IM590) Crude Oil Tanker 159,711DWT 81,479GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9172052; MMSI
677049000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
MAGNOLIA (a.k.a. SABRINA; f.k.a. SARVESTAN) (5IM590) Crude Oil Tanker 159,711DWT 81,479GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9172052; MMSI
677049000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SWALLOW (f.k.a. CAMELLIA; f.k.a. SAVEH) (5IM 594) Crude Oil Tanker 159,758DWT 81,479GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9171462; MMSI
677049400 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SAVEH (f.k.a. CAMELLIA; a.k.a. SWALLOW) (5IM 594) Crude Oil Tanker 159,758DWT 81,479GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9171462; MMSI
677049400 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
CAMELLIA (f.k.a. SAVEH; a.k.a. SWALLOW) (5IM 594) Crude Oil Tanker 159,758DWT 81,479GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9171462; MMSI
677049400 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SPARROW (f.k.a. CLOVE; f.k.a. SEMNAN) (5IM 595) Crude Oil Tanker 159,681DWT 81,479GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9171450; MMSI
677049500 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SEMNAN (f.k.a. CLOVE; a.k.a. SPARROW) (5IM 595) Crude Oil Tanker 159,681DWT 81,479GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9171450; MMSI
677049500 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
CLOVE (f.k.a. SEMNAN; a.k.a. SPARROW) (5IM 595) Crude Oil Tanker 159,681DWT 81,479GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9171450; MMSI
677049500 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SANCHI (f.k.a. GARDENIA; f.k.a. SEAHORSE; f.k.a. SEPID) (T2EF4) Crude Oil Tanker 164,154DWT 85,462GRT None Identified flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9356608; MMSI 572455210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SEPID (f.k.a. GARDENIA; a.k.a. SANCHI; f.k.a. SEAHORSE) (T2EF4) Crude Oil Tanker 164,154DWT 85,462GRT None Identified flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9356608; MMSI 572455210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
GARDENIA (a.k.a. SANCHI; f.k.a. SEAHORSE; f.k.a. SEPID) (T2EF4) Crude Oil Tanker 164,154DWT 85,462GRT None Identified flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9356608; MMSI 572455210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SEAHORSE (f.k.a. GARDENIA; a.k.a. SANCHI; f.k.a. SEPID) (T2EF4) Crude Oil Tanker 164,154DWT 85,462GRT None Identified flag; Former Vessel
Flag Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For
more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9356608; MMSI 572455210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 64/83
SUCCESS (f.k.a. BAIKAL; f.k.a. BLOSSOM; f.k.a. SIMA) (T2DY4) Crude Oil Tanker 164,154DWT 85,462GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9357353; MMSI 572449210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SIMA (f.k.a. BAIKAL; f.k.a. BLOSSOM; a.k.a. SUCCESS) (T2DY4) Crude Oil Tanker 164,154DWT 85,462GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9357353; MMSI 572449210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BLOSSOM (f.k.a. BAIKAL; f.k.a. SIMA; a.k.a. SUCCESS) (T2DY4) Crude Oil Tanker 164,154DWT 85,462GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9357353; MMSI 572449210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BAIKAL (f.k.a. BLOSSOM; f.k.a. SIMA; a.k.a. SUCCESS) (T2DY4) Crude Oil Tanker 164,154DWT 85,462GRT None Identified flag; Former Vessel Flag
Malta; alt. Former Vessel Flag Tuvalu; alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9357353; MMSI 572449210 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SUNEAST (f.k.a. AZALEA; f.k.a. SINA) (9HNY9) Crude Oil Tanker 164,154DWT 85,462GRT Seychelles flag; Former Vessel Flag Malta; alt. Former
Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357365;
MMSI 249256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SINA (f.k.a. AZALEA; a.k.a. SUNEAST) (9HNY9) Crude Oil Tanker 164,154DWT 85,462GRT Seychelles flag; Former Vessel Flag Malta; alt. Former
Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357365;
MMSI 249256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
AZALEA (f.k.a. SINA; a.k.a. SUNEAST) (9HNY9) Crude Oil Tanker 164,154DWT 85,462GRT Seychelles flag; Former Vessel Flag Malta; alt. Former
Vessel Flag Tuvalu; alt. Former Vessel Flag None Identified; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357365;
MMSI 249256000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SMOOTH (a.k.a. YARD NO. 1225 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT None Identified flag; Former Vessel Flag
Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this
Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9569657 (vessel) [IRAN] (Linked To: NATIONAL
IRANIAN TANKER COMPANY).
YARD NO. 1225 SHANGHAI WAIGAOQIAO (a.k.a. SMOOTH) Crude Oil Tanker 318,000DWT 165,000GRT None Identified flag; Former Vessel Flag
Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this
Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9569657 (vessel) [IRAN] (Linked To: NATIONAL
IRANIAN TANKER COMPANY).
FORTUN (f.k.a. SONATA; a.k.a. YARD NO. 1222 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT None Identified flag; Former
Vessel Flag Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569633 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YARD NO. 1222 SHANGHAI WAIGAOQIAO (a.k.a. FORTUN; f.k.a. SONATA) Crude Oil Tanker 318,000DWT 165,000GRT None Identified flag; Former
Vessel Flag Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to
Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569633 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SONATA (a.k.a. FORTUN; a.k.a. YARD NO. 1222 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT None Identified flag;
Former Vessel Flag Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569633 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 65/83
SALALEH (f.k.a. SONGBIRD; a.k.a. YARD NO. 1224 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT None Identified flag;
Former Vessel Flag Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569645 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YARD NO. 1224 SHANGHAI WAIGAOQIAO (a.k.a. SALALEH; f.k.a. SONGBIRD) Crude Oil Tanker 318,000DWT 165,000GRT None Identified flag;
Former Vessel Flag Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569645 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SONGBIRD (a.k.a. SALALEH; a.k.a. YARD NO. 1224 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT None Identified flag;
Former Vessel Flag Malta; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569645 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DOJRAN (f.k.a. RAINBOW; f.k.a. SOUVENIR; a.k.a. YARD NO. 1221 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT
Tanzania flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9569619 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YARD NO. 1221 SHANGHAI WAIGAOQIAO (a.k.a. DOJRAN; f.k.a. RAINBOW; f.k.a. SOUVENIR) Crude Oil Tanker 318,000DWT 165,000GRT
Tanzania flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9569619 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SOUVENIR (a.k.a. DOJRAN; f.k.a. RAINBOW; a.k.a. YARD NO. 1221 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT
Tanzania flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9569619 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
RAINBOW (a.k.a. DOJRAN; f.k.a. SOUVENIR; a.k.a. YARD NO. 1221 SHANGHAI WAIGAOQIAO) Crude Oil Tanker 318,000DWT 165,000GRT
Tanzania flag; Former Vessel Flag Malta; alt. Former Vessel Flag Tuvalu; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 9569619 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SUPERIOR (f.k.a. DAISY; f.k.a. SUSANGIRD) (5IM584) Crude Oil Tanker 159,681DWT 81,479GRT None Identified flag; Former Vessel Flag Malta; alt.
Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9172038; MMSI
677048400 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SUSANGIRD (f.k.a. DAISY; a.k.a. SUPERIOR) (5IM584) Crude Oil Tanker 159,681DWT 81,479GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9172038; MMSI
677048400 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DAISY (a.k.a. SUPERIOR; f.k.a. SUSANGIRD) (5IM584) Crude Oil Tanker 159,681DWT 81,479GRT None Identified flag; Former Vessel Flag Malta;
alt. Former Vessel Flag Tanzania; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9172038; MMSI
677048400 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
TOLOU (EQOD) Crew/Supply Vessel 250DWT 178GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 8318178
(vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
VALFAJR2 (EQOX) Tug 650DWT 419GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions;
U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please
see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 8400103
(vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YAGHOUB (EQOE) Platform Supply Ship 950DWT 1,019GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 66/83
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 8316168; MMSI 422150000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
YANGZHOU DAYANG DY905 (a.k.a. YARD NO. DY905 YANGZHOU D.) LPG Tanker 11,750DWT 8,750GRT Iran flag; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9575424 (vessel) [IRAN] (Linked To: NATIONAL
IRANIAN TANKER COMPANY).
YARD NO. DY905 YANGZHOU D. (a.k.a. YANGZHOU DAYANG DY905) LPG Tanker 11,750DWT 8,750GRT Iran flag; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Vessel Registration Identification IMO 9575424 (vessel) [IRAN] (Linked To: NATIONAL
IRANIAN TANKER COMPANY).
YOUSEF (EQOG) Offshore Tug/Supply Ship 1,050DWT 584GRT Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification
IMO 8316106; MMSI 422144000 (vessel) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NATIONAL IRANIAN TANKER COMPANY (a.k.a. NITC), NITC Building, 67-88, Shahid Atefi Street, Africa Avenue, Tehran, Iran; Website www.nitc.co.ir;
Email Address [email protected]; alt. Email Address [email protected]; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone (98)(21)
(66153220); Telephone (98)(21)(23803202); Telephone (98)(21)(23803303); Telephone (98)(21)(66153224); Telephone (98)(21)(23802230);
Telephone (98)(9121115315); Telephone (98)(9128091642); Telephone (98)(9127389031); Fax (98)(21)(22224537); Fax (98)(21)(23803318); Fax (98)
(21)(22013392); Fax (98)(21)(22058763) [IRAN].
NITC (a.k.a. NATIONAL IRANIAN TANKER COMPANY), NITC Building, 67-88, Shahid Atefi Street, Africa Avenue, Tehran, Iran; Website www.nitc.co.ir;
Email Address [email protected]; alt. Email Address [email protected]; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone (98)(21)
(66153220); Telephone (98)(21)(23803202); Telephone (98)(21)(23803303); Telephone (98)(21)(66153224); Telephone (98)(21)(23802230);
Telephone (98)(9121115315); Telephone (98)(9128091642); Telephone (98)(9127389031); Fax (98)(21)(22224537); Fax (98)(21)(23803318); Fax (98)
(21)(22013392); Fax (98)(21)(22058763) [IRAN].
NATIONAL IRANIAN TANKER COMPANY LLC (a.k.a. NATIONAL IRANIAN TANKER COMPANY LLC SHARJAH BRANCH; a.k.a. NITC SHARJAH), Al
Wahda Street, Street No. 4, Sharjah, United Arab Emirates; P.O. Box 3267, Sharjah, United Arab Emirates; Website http://nitcsharjah.com/index.html;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone +97165030600; Telephone + 97165749996; Telephone +971506262258; Fax
+97165394666; Fax +97165746661 [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NATIONAL IRANIAN TANKER COMPANY LLC SHARJAH BRANCH (a.k.a. NATIONAL IRANIAN TANKER COMPANY LLC; a.k.a. NITC SHARJAH), Al
Wahda Street, Street No. 4, Sharjah, United Arab Emirates; P.O. Box 3267, Sharjah, United Arab Emirates; Website http://nitcsharjah.com/index.html;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone +97165030600; Telephone + 97165749996; Telephone +971506262258; Fax
+97165394666; Fax +97165746661 [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NITC SHARJAH (a.k.a. NATIONAL IRANIAN TANKER COMPANY LLC; a.k.a. NATIONAL IRANIAN TANKER COMPANY LLC SHARJAH BRANCH), Al
Wahda Street, Street No. 4, Sharjah, United Arab Emirates; P.O. Box 3267, Sharjah, United Arab Emirates; Website http://nitcsharjah.com/index.html;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone +97165030600; Telephone + 97165749996; Telephone +971506262258; Fax
+97165394666; Fax +97165746661 [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
N.I.T.C. REPRESENTATIVE OFFICE (a.k.a. NATIONAL IRANIAN TANKER COMPANY), Droogdokweg 71, Rotterdam 3089 JN, Netherlands; Email
Address [email protected]; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone +31 010-4951863; Telephone +31 10-4360037;
Fax +31 10-4364096 [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
NATIONAL IRANIAN TANKER COMPANY (a.k.a. N.I.T.C. REPRESENTATIVE OFFICE), Droogdokweg 71, Rotterdam 3089 JN, Netherlands; Email
Address [email protected]; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone +31 010-4951863; Telephone +31 10-4360037;
Fax +31 10-4364096 [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
ARTA SHIPPING ENTERPRISES LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 67/83
center/sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22678777) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
ARASH SHIPPING ENTERPRISES LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22678777) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
PROTON PETROCHEMICALS SHIPPING LIMITED (a.k.a. PROTON SHIPPING CO; a.k.a. "PSC"), Diagoras House, 7th Floor, 16 Panteli Katelari
Street, Nicosia 1097, Cyprus; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone (357)(22660766); Fax (357)(22668608) [IRAN]
(Linked To: NATIONAL IRANIAN TANKER COMPANY).
PROTON SHIPPING CO (a.k.a. PROTON PETROCHEMICALS SHIPPING LIMITED; a.k.a. "PSC"), Diagoras House, 7th Floor, 16 Panteli Katelari
Street, Nicosia 1097, Cyprus; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone (357)(22660766); Fax (357)(22668608) [IRAN]
(Linked To: NATIONAL IRANIAN TANKER COMPANY).
"PSC" (a.k.a. PROTON PETROCHEMICALS SHIPPING LIMITED; a.k.a. PROTON SHIPPING CO), Diagoras House, 7th Floor, 16 Panteli Katelari
Street, Nicosia 1097, Cyprus; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone (357)(22660766); Fax (357)(22668608) [IRAN]
(Linked To: NATIONAL IRANIAN TANKER COMPANY).
DANESH SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
DAVAR SHIPPING CO LTD, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22678777) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
HADI SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
HARAZ SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
HATEF SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
HIRMAND SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
HODA SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
HOMA SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 68/83
center/sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
HONAR SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
TC SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
MEHRAN SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
MERSAD SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
SAMAN SHIPPING COMPANY LIMITED, Diagoras House, 7th Floor, 16 Panteli Katelari Street, Nicosia 1097, Cyprus; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(22660766); Fax (357)(22668608) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
ASAN SHIPPING ENTERPRISE LIMITED, 85 St. John Street, Valletta VLT 1165, Malta; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone
(356)(21241817); Fax (356)(25990640) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SARV SHIPPING COMPANY LIMITED, 198 Old Bakery Street, Valletta VLT 1455, Malta; Additional Sanctions Information - Not on the SDN List and
Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone
(356)(21241232) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SEPID SHIPPING COMPANY LIMITED, 198 Old Bakery Street, Valletta VLT 1455, Malta; Additional Sanctions Information - Not on the SDN List and
Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone
(356)(21241232) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SIMA SHIPPING COMPANY LIMITED, 198 Old Bakery Street, Valletta VLT 1455, Malta; Additional Sanctions Information - Not on the SDN List and
Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone
(356)(21241232) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
SINA SHIPPING COMPANY LIMITED, 198 Old Bakery Street, Valletta VLT 1455, Malta; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone
(356)(21241232) [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
CASPIAN MARITIME LIMITED, Fortuna Court, Block B, 284 Archbishop Makarios II Avenue, Limassol 3105, Cyprus; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Telephone (357)(25800000); Fax (357)(25588055) [IRAN] (Linked To: NATIONAL IRANIAN
TANKER COMPANY).
MINAB SHIPPING COMPANY LIMITED (f.k.a. MIGHAT SHIPPING COMPANY LIMITED), Diagoras House, 7th Floor, 16 Panteli Katelari Street,
Nicosia 1097, Cyprus; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone (357)(22660766); Fax (357)(22668608) [IRAN]
(Linked To: NATIONAL IRANIAN TANKER COMPANY).
MIGHAT SHIPPING COMPANY LIMITED (a.k.a. MINAB SHIPPING COMPANY LIMITED), Diagoras House, 7th Floor, 16 Panteli Katelari Street,
Nicosia 1097, Cyprus; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 69/83
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone (357)(22660766); Fax (357)(22668608) [IRAN]
(Linked To: NATIONAL IRANIAN TANKER COMPANY).
PARS PETROCHEMICAL SHIPPING COMPANY, 1st Floor, No. 19, Shenasa Street, Vali E Asr Avenue, Tehran, Iran; Website www.parsshipping.com;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
DENA TANKERS FZE, Free Zone, P.O. Box 5232 , Fujairah, United Arab Emirates; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN]
(Linked To: NATIONAL IRANIAN TANKER COMPANY).
PETRO SUISSE INTERTRADE COMPANY SA, 6 Avenue de la Tour-Haldimand, Pully 1009, Switzerland; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
HONG KONG INTERTRADE COMPANY, Hong Kong; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions;
U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
NOOR ENERGY (MALAYSIA) LTD., Labuan, Malaysia; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Company Number LL08318 [IRAN].
PETRO ENERGY INTERTRADE COMPANY, Dubai, United Arab Emirates; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SIMA GENERAL TRADING CO FZE (a.k.a. SIMA GENERAL TRADING & INDUSTRIALS FOR BUILDING MATERIAL CO FZE), Office No. 703 Office
Tower, Twin Tower, Baniyas Rd., Deira, P.O. Box 49754, Dubai, United Arab Emirates; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SIMA GENERAL TRADING & INDUSTRIALS FOR BUILDING MATERIAL CO FZE (a.k.a. SIMA GENERAL TRADING CO FZE), Office No. 703 Office
Tower, Twin Tower, Baniyas Rd., Deira, P.O. Box 49754, Dubai, United Arab Emirates; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
POLINEX GENERAL TRADING LLC, Health Care City, Umm Hurair Rd., Oud Mehta Offices, Block A, 4th Floor 420, Dubai, United Arab Emirates;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
ASIA ENERGY GENERAL TRADING (LLC), Suite 703, Twin Tower, Baniyas Street, Deira, Dubai, United Arab Emirates; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SYNERGY GENERAL TRADING FZE, Sharjah - Saif Zone, Sharjah Airport International Free Zone, United Arab Emirates; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
CAMBIS, Dimitris (a.k.a. KAMPIS, Dimitrios Alexandros; a.k.a. "KLIMT, Gustav"); DOB 14 Oct 1963; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
(individual) [IRAN].
KAMPIS, Dimitrios Alexandros (a.k.a. CAMBIS, Dimitris; a.k.a. "KLIMT, Gustav"); DOB 14 Oct 1963; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
(individual) [IRAN].
"KLIMT, Gustav" (a.k.a. CAMBIS, Dimitris; a.k.a. KAMPIS, Dimitrios Alexandros); DOB 14 Oct 1963; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
(individual) [IRAN].
IMPIRE SHIPPING COMPANY (a.k.a. IMPIRE SHIPPING; a.k.a. IMPIRE SHIPPING LIMITED), Greece; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 70/83
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
IMPIRE SHIPPING LIMITED (a.k.a. IMPIRE SHIPPING; a.k.a. IMPIRE SHIPPING COMPANY), Greece; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
IMPIRE SHIPPING (a.k.a. IMPIRE SHIPPING COMPANY; a.k.a. IMPIRE SHIPPING LIMITED), Greece; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
AURA (f.k.a. OCEAN PERFORMER) Crude Oil Tanker Mongolia flag; Former Vessel Flag Liberia; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9013749 (vessel) [IRAN].
OCEAN PERFORMER (a.k.a. AURA) Crude Oil Tanker Mongolia flag; Former Vessel Flag Liberia; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9013749 (vessel) [IRAN].
BRIGHT (f.k.a. ZAP) Crude Oil Tanker Mongolia flag; Former Vessel Flag Liberia; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9005235 (vessel) [IRAN].
ZAP (a.k.a. BRIGHT) Crude Oil Tanker Mongolia flag; Former Vessel Flag Liberia; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration
Identification IMO 9005235 (vessel) [IRAN].
ATLANTIC (f.k.a. SEAGULL) Crude Oil Tanker Liberia flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9107655
(vessel) [IRAN].
SEAGULL (a.k.a. ATLANTIC) Crude Oil Tanker Liberia flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9107655
(vessel) [IRAN].
DESTINY (f.k.a. ULYSSES 1) Crude Oil Tanker Mongolia flag; Former Vessel Flag Liberia; Additional Sanctions Information - Not on the SDN List and
Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order
13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9177155 (vessel) [IRAN].
ULYSSES 1 (a.k.a. DESTINY) Crude Oil Tanker Mongolia flag; Former Vessel Flag Liberia; Additional Sanctions Information - Not on the SDN List and
Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order
13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9177155 (vessel) [IRAN].
BICAS (f.k.a. GLAROS) Crude Oil Tanker Liberia flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions;
U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please
see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9077850
(vessel) [IRAN].
GLAROS (a.k.a. BICAS) Crude Oil Tanker Liberia flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions;
U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please
see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9077850
(vessel) [IRAN].
ORIENTAL (f.k.a. LEYCOTHEA) Crude Oil Tanker Unknown flag; Former Vessel Flag Panama; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9183934 (vessel) [IRAN].
LEYCOTHEA (a.k.a. ORIENTAL) Crude Oil Tanker Unknown flag; Former Vessel Flag Panama; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9183934 (vessel) [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 71/83
HUMANITY (f.k.a. OCEAN NYMPH) Crude Oil Tanker Mongolia flag; Former Vessel Flag Panama; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9180281 (vessel) [IRAN].
OCEAN NYMPH (a.k.a. HUMANITY) Crude Oil Tanker Mongolia flag; Former Vessel Flag Panama; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel
Registration Identification IMO 9180281 (vessel) [IRAN].
CARIBO (f.k.a. NEREYDA) Crude Oil Tanker Panama flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9011246
(vessel) [IRAN].
NEREYDA (a.k.a. CARIBO) Crude Oil Tanker Panama flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9011246
(vessel) [IRAN].
GRACE BAY SHIPPING INC, Care of Sambouk Shipping FCZ, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044, Fujairah, United
Arab Emirates; Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro MH96960, Marshall Islands; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
GARBIN NAVIGATION LTD, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044, Fujairah,
United Arab Emirates; 80 Broad Street, Monrovia, Liberia; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
MONSOON SHIPPING LTD, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044,
Fujairah, United Arab Emirates; Valletta, Malta; Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro MH96960, Marshall Islands;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
KONING MARINE CORP, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044, Fujairah,
United Arab Emirates; 80 Broad Street, Monrovia, Liberia; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BLUE TANKER SHIPPING SA, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044,
Fujairah, United Arab Emirates; Majuro MH, Marshall Islands; Liberia; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
JUPITER SEAWAYS SHIPPING, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044,
Fujairah, United Arab Emirates; 80 Broad Street, Monrovia, Liberia; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
HERCULES INTERNATIONAL SHIP, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044,
Fujairah, United Arab Emirates; 80 Broad Street, Monrovia, Liberia; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
HERMIS SHIPPING SA, Care of Sambouk Shipping FCZ, Office 101, 1st Floor, FITCO Building No 3, Inside Fujairah Port, PO Box 50044, Fujairah,
United Arab Emirates; Panama City, Panama; Monrovia, Liberia; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SAMBOUK SHIPPING FZC, FITCO Building No. 3, Office 101, 1st Floor, P.O. Box 50044, Fujairah, United Arab Emirates; Office 1202, Crystal Plaza,
PO Box 50044, Buhaira Corniche, Sharjah, United Arab Emirates; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BADR (EQJU) Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 8407345 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 72/83
ATLANTIS (5IM316) Crude Oil Tanker Tanzania flag (NITC); Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569621
(vessel) [IRAN].
DEMOS (5IM656) Crude Oil Tanker Tanzania flag (NITC); Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569683
(vessel) [IRAN].
INFINITY (5IM411) Crude Oil Tanker Tanzania flag (NITC); Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569671
(vessel) [IRAN].
SUNRISE LPG Tanker None Identified flag (NITC); Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions;
U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please
see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9615092
(vessel) [IRAN].
SKYLINE (5IM632) Crude Oil Tanker Tanzania flag (NITC); Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9569669
(vessel) [IRAN].
YOUNES (EQYY) Platform Supply Ship Iran flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 8212465 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
JUSTICE Crude Oil Tanker None Identified flag; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block this Property and Interests in this Property Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Vessel Registration Identification IMO 9357729 (vessel)
[IRAN] (Linked To: NATIONAL IRANIAN TANKER COMPANY).
BANDAR IMAM PETROCHEMICAL COMPANY, North Kargar Street, Tehran, Iran; Mahshahr, Bandar Imam, Khuzestan Province, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BOU ALI SINA PETROCHEMICAL COMPANY (a.k.a. BUALI SINA PETROCHEMICAL COMPANY), No. 17, 1st Floor, Daman Afshar St., Vanak Sq.,
Vali-e-Asr Ave, Tehran 19697, Iran; Petrochemical Special Economic Zone (PETZONE), Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
BUALI SINA PETROCHEMICAL COMPANY (a.k.a. BOU ALI SINA PETROCHEMICAL COMPANY), No. 17, 1st Floor, Daman Afshar St., Vanak Sq.,
Vali-e-Asr Ave, Tehran 19697, Iran; Petrochemical Special Economic Zone (PETZONE), Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
MOBIN PETROCHEMICAL COMPANY, South Pars Special Economic Energy Zone, Postal Box: 75391-418, Assaluyeh, Bushehr, Iran; PO Box,
Mashhad, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block
the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
NOURI PETROCHEMICAL COMPANY (a.k.a. BORZUYEH PETROCHEMICAL COMPANY; a.k.a. NOURI PETROCHEMICAL COMPLEX), Pars
Special Economic Energy Zone, Assaluyeh Port, Bushehr, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BORZUYEH PETROCHEMICAL COMPANY (a.k.a. NOURI PETROCHEMICAL COMPANY; a.k.a. NOURI PETROCHEMICAL COMPLEX), Pars
Special Economic Energy Zone, Assaluyeh Port, Bushehr, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
NOURI PETROCHEMICAL COMPLEX (a.k.a. BORZUYEH PETROCHEMICAL COMPANY; a.k.a. NOURI PETROCHEMICAL COMPANY), Pars
Special Economic Energy Zone, Assaluyeh Port, Bushehr, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 73/83
PARS PETROCHEMICAL COMPANY, Pars Special Economic Energy Zone, PO Box 163-75391, Assaluyeh, Bushehr, Iran; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SHAHID TONDGOOYAN PETROCHEMICAL COMPANY (a.k.a. SHAHID TONDGUYAN PETROCHEMICAL COMPANY), Petrochemical Special
Economic Zone (PETZONE), Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SHAHID TONDGUYAN PETROCHEMICAL COMPANY (a.k.a. SHAHID TONDGOOYAN PETROCHEMICAL COMPANY), Petrochemical Special
Economic Zone (PETZONE), Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SHAZAND PETROCHEMICAL COMPANY (a.k.a. AR.P.C.; a.k.a. ARAK PETROCHEMICAL COMPANY; a.k.a. SHAZAND PETROCHEMICAL
CORPORATION), No. 68, Taban St., Vali Asr Ave., Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
AR.P.C. (a.k.a. ARAK PETROCHEMICAL COMPANY; a.k.a. SHAZAND PETROCHEMICAL COMPANY; a.k.a. SHAZAND PETROCHEMICAL
CORPORATION), No. 68, Taban St., Vali Asr Ave., Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SHAZAND PETROCHEMICAL CORPORATION (a.k.a. AR.P.C.; a.k.a. ARAK PETROCHEMICAL COMPANY; a.k.a. SHAZAND PETROCHEMICAL
COMPANY), No. 68, Taban St., Vali Asr Ave., Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
ARAK PETROCHEMICAL COMPANY (a.k.a. AR.P.C.; a.k.a. SHAZAND PETROCHEMICAL COMPANY; a.k.a. SHAZAND PETROCHEMICAL
CORPORATION), No. 68, Taban St., Vali Asr Ave., Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TABRIZ PETROCHEMICAL COMPANY, Off Km 8, Azarshahr Road, Kojuvar Road, Tabriz, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
GHALEBANI, Ahmad (a.k.a. GHALEHBANI, Ahmad; a.k.a. QALEHBANI, Ahmad); DOB 01 Jan 1953 to 31 Dec 1954; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Passport H20676140 (Iran); Managing Director, National Iranian Oil Company; Director, Hong
Kong Intertrade Company; Director, Petro Suisse Intertrade Company (individual) [IRAN].
GHALEHBANI, Ahmad (a.k.a. GHALEBANI, Ahmad; a.k.a. QALEHBANI, Ahmad); DOB 01 Jan 1953 to 31 Dec 1954; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Passport H20676140 (Iran); Managing Director, National Iranian Oil Company; Director, Hong
Kong Intertrade Company; Director, Petro Suisse Intertrade Company (individual) [IRAN].
QALEHBANI, Ahmad (a.k.a. GHALEBANI, Ahmad; a.k.a. GHALEHBANI, Ahmad); DOB 01 Jan 1953 to 31 Dec 1954; Additional Sanctions Information
- Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Passport H20676140 (Iran); Managing Director, National Iranian Oil Company; Director, Hong
Kong Intertrade Company; Director, Petro Suisse Intertrade Company (individual) [IRAN].
JASHNSAZ, Seifollah (a.k.a. JASHN SAZ, Seifollah; a.k.a. JASHNSAZ, Seyfollah); DOB 22 Mar 1958; POB Behbahan, Iran; nationality Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Passport R17589399 (Iran); alt. Passport T23700825 (Iran); Chairman & Director, Naftiran
Intertrade Co. (NICO) Sarl; Chairman & Director, Naft Iran Intertrade Company Ltd.; Director, Hong Kong Intertrade Company; Chairman of the Board
of Directors, Iranian Oil Company (U.K.) Limited; Chairman & Director, Petro Suisse Intertrade Company (individual) [IRAN].
JASHNSAZ, Seyfollah (a.k.a. JASHN SAZ, Seifollah; a.k.a. JASHNSAZ, Seifollah); DOB 22 Mar 1958; POB Behbahan, Iran; nationality Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Passport R17589399 (Iran); alt. Passport T23700825 (Iran); Chairman & Director, Naftiran
Intertrade Co. (NICO) Sarl; Chairman & Director, Naft Iran Intertrade Company Ltd.; Director, Hong Kong Intertrade Company; Chairman of the Board
of Directors, Iranian Oil Company (U.K.) Limited; Chairman & Director, Petro Suisse Intertrade Company (individual) [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 74/83
JASHN SAZ, Seifollah (a.k.a. JASHNSAZ, Seifollah; a.k.a. JASHNSAZ, Seyfollah); DOB 22 Mar 1958; POB Behbahan, Iran; nationality Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Passport R17589399 (Iran); alt. Passport T23700825 (Iran); Chairman & Director, Naftiran
Intertrade Co. (NICO) Sarl; Chairman & Director, Naft Iran Intertrade Company Ltd.; Director, Hong Kong Intertrade Company; Chairman of the Board
of Directors, Iranian Oil Company (U.K.) Limited; Chairman & Director, Petro Suisse Intertrade Company (individual) [IRAN].
NIKOUSOKHAN, Mahmoud; DOB 01 Jan 1961 to 31 Dec 1962; nationality Iran; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order
13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Passport
U14624657 (Iran); Finance Director, National Iranian Oil Company; Director, Hong Kong Intertrade Company; Director, Petro Suisse Intertrade
Company (individual) [IRAN].
BAZARGAN, Farzad; DOB 03 Jun 1956; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Passport D14855558 (Iran); alt. Passport Y21130717 (Iran);
Managing Director, Hong Kong Intertrade Company (individual) [IRAN].
POURANSARI, Hashem; nationality Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Passport B19488852 (Iran); Managing Director,
Asia Energy General Trading (individual) [IRAN].
BAHADORI, Masoud; nationality Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Passport T12828814 (Iran); Managing Director, Petro
Suisse Intertrade Company (individual) [IRAN].
EXECUTION OF IMAM KHOMEINI'S ORDER (a.k.a. EIKO; a.k.a. SETAD; a.k.a. SETAD EJRAEI EMAM; a.k.a. SETAD-E EJRAEI-E FARMAN-E
HAZRAT-E EMAM; a.k.a. SETAD-E FARMAN-EJRAEI-YE EMAM), Khaled Stamboli St., Tehran, Iran; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
EIKO (a.k.a. EXECUTION OF IMAM KHOMEINI'S ORDER; a.k.a. SETAD; a.k.a. SETAD EJRAEI EMAM; a.k.a. SETAD-E EJRAEI-E FARMAN-E
HAZRAT-E EMAM; a.k.a. SETAD-E FARMAN-EJRAEI-YE EMAM), Khaled Stamboli St., Tehran, Iran; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SETAD (a.k.a. EIKO; a.k.a. EXECUTION OF IMAM KHOMEINI'S ORDER; a.k.a. SETAD EJRAEI EMAM; a.k.a. SETAD-E EJRAEI-E FARMAN-E
HAZRAT-E EMAM; a.k.a. SETAD-E FARMAN-EJRAEI-YE EMAM), Khaled Stamboli St., Tehran, Iran; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SETAD-E EJRAEI-E FARMAN-E HAZRAT-E EMAM (a.k.a. EIKO; a.k.a. EXECUTION OF IMAM KHOMEINI'S ORDER; a.k.a. SETAD; a.k.a. SETAD
EJRAEI EMAM; a.k.a. SETAD-E FARMAN-EJRAEI-YE EMAM), Khaled Stamboli St., Tehran, Iran; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
SETAD-E FARMAN-EJRAEI-YE EMAM (a.k.a. EIKO; a.k.a. EXECUTION OF IMAM KHOMEINI'S ORDER; a.k.a. SETAD; a.k.a. SETAD EJRAEI
EMAM; a.k.a. SETAD-E EJRAEI-E FARMAN-E HAZRAT-E EMAM), Khaled Stamboli St., Tehran, Iran; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SETAD EJRAEI EMAM (a.k.a. EIKO; a.k.a. EXECUTION OF IMAM KHOMEINI'S ORDER; a.k.a. SETAD; a.k.a. SETAD-E EJRAEI-E FARMAN-E
HAZRAT-E EMAM; a.k.a. SETAD-E FARMAN-EJRAEI-YE EMAM), Khaled Stamboli St., Tehran, Iran; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
TOSEE EQTESAD AYANDEHSAZAN COMPANY (a.k.a. TEACO; a.k.a. TOSEE EGHTESAD AYANDEHSAZAN COMPANY), 39 Gandhi Avenue,
Tehran 1517883115, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TEACO (a.k.a. TOSEE EGHTESAD AYANDEHSAZAN COMPANY; a.k.a. TOSEE EQTESAD AYANDEHSAZAN COMPANY), 39 Gandhi Avenue,
Tehran 1517883115, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 75/83
TOSEE EGHTESAD AYANDEHSAZAN COMPANY (a.k.a. TEACO; a.k.a. TOSEE EQTESAD AYANDEHSAZAN COMPANY), 39 Gandhi Avenue,
Tehran 1517883115, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TADBIR ECONOMIC DEVELOPMENT GROUP (a.k.a. TADBIR GROUP), 16 Avenue Bucharest, Tehran, Iran; Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
TADBIR GROUP (a.k.a. TADBIR ECONOMIC DEVELOPMENT GROUP), 16 Avenue Bucharest, Tehran, Iran; Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
TADBIR INVESTMENT COMPANY, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
MODABER (a.k.a. MODABER INVESTMENT COMPANY; a.k.a. TADBIR INDUSTRIAL HOLDING COMPANY); Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
TADBIR INDUSTRIAL HOLDING COMPANY (a.k.a. MODABER; a.k.a. MODABER INVESTMENT COMPANY); Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
MODABER INVESTMENT COMPANY (a.k.a. MODABER; a.k.a. TADBIR INDUSTRIAL HOLDING COMPANY); Additional Sanctions Information - Not
on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
TADBIR CONSTRUCTION DEVELOPMENT COMPANY (a.k.a. GORUH-E TOSE-E SAKHTEMAN-E TADBIR; a.k.a. TADBIR BUILDING EXPANSION
GROUP; a.k.a. TADBIR HOUSING DEVELOPMENT GROUP), Block 1, Mehr Passage, 4th Street, Iran Zamin Boulevard, Shahrak Qods, Tehran,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TADBIR HOUSING DEVELOPMENT GROUP (a.k.a. GORUH-E TOSE-E SAKHTEMAN-E TADBIR; a.k.a. TADBIR BUILDING EXPANSION GROUP;
a.k.a. TADBIR CONSTRUCTION DEVELOPMENT COMPANY), Block 1, Mehr Passage, 4th Street, Iran Zamin Boulevard, Shahrak Qods, Tehran,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
GORUH-E TOSE-E SAKHTEMAN-E TADBIR (a.k.a. TADBIR BUILDING EXPANSION GROUP; a.k.a. TADBIR CONSTRUCTION DEVELOPMENT
COMPANY; a.k.a. TADBIR HOUSING DEVELOPMENT GROUP), Block 1, Mehr Passage, 4th Street, Iran Zamin Boulevard, Shahrak Qods, Tehran,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TADBIR BUILDING EXPANSION GROUP (a.k.a. GORUH-E TOSE-E SAKHTEMAN-E TADBIR; a.k.a. TADBIR CONSTRUCTION DEVELOPMENT
COMPANY; a.k.a. TADBIR HOUSING DEVELOPMENT GROUP), Block 1, Mehr Passage, 4th Street, Iran Zamin Boulevard, Shahrak Qods, Tehran,
Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TADBIR ENERGY DEVELOPMENT GROUP CO., 6th Floor, Mirdamad Avenue, No. 346, Tehran, Iran; Website http://www.tadbirenergy.com; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
REY INVESTMENT COMPANY, 2nd and 3rd Floors, No. 14, Saba Boulevard, After Esfandiar Crossroad, Africa Boulevard, Tehran 1918973657, Iran;
Website http://www.rey-co.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
REYCO GMBH. (a.k.a. REYCO GMBH GERMANY), Karlstrasse 19, Dinslaken, Nordrhein-Westfalen 46535, Germany; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 76/83
REYCO GMBH GERMANY (a.k.a. REYCO GMBH.), Karlstrasse 19, Dinslaken, Nordrhein-Westfalen 46535, Germany; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
MCS INTERNATIONAL GMBH (a.k.a. MANNESMAN CYLINDER SYSTEMS; a.k.a. MCS TECHNOLOGIES GMBH), Karlstrasse 23-25, Dinslaken,
Nordrhein-Westfalen 46535, Germany; Website http://www.mcs-tch.com; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
MANNESMAN CYLINDER SYSTEMS (a.k.a. MCS INTERNATIONAL GMBH; a.k.a. MCS TECHNOLOGIES GMBH), Karlstrasse 23-25, Dinslaken,
Nordrhein-Westfalen 46535, Germany; Website http://www.mcs-tch.com; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
MCS TECHNOLOGIES GMBH (a.k.a. MANNESMAN CYLINDER SYSTEMS; a.k.a. MCS INTERNATIONAL GMBH), Karlstrasse 23-25, Dinslaken,
Nordrhein-Westfalen 46535, Germany; Website http://www.mcs-tch.com; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
MCS ENGINEERING (a.k.a. EFFICIENT PROVIDER SERVICES GMBH), Karlstrasse 21, Dinslaken, Nordrhein-Westfalen 46535, Germany; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
EFFICIENT PROVIDER SERVICES GMBH (a.k.a. MCS ENGINEERING), Karlstrasse 21, Dinslaken, Nordrhein-Westfalen 46535, Germany; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
GOLDEN RESOURCES TRADING COMPANY L.L.C. (a.k.a. "GRTC"), 9th Floor, Office No. 905, Khalid Al Attar Tower 1, Sheikh Zayed Road, After
Crown Plaza Hotel, Al Wasl Area, Dubai, United Arab Emirates; Postal Box 34489, Dubai, United Arab Emirates; Postal Box 14358, Dubai, United
Arab Emirates; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block
the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
"GRTC" (a.k.a. GOLDEN RESOURCES TRADING COMPANY L.L.C.), 9th Floor, Office No. 905, Khalid Al Attar Tower 1, Sheikh Zayed Road, After
Crown Plaza Hotel, Al Wasl Area, Dubai, United Arab Emirates; Postal Box 34489, Dubai, United Arab Emirates; Postal Box 14358, Dubai, United
Arab Emirates; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block
the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
CYLINDER SYSTEM L.T.D. (a.k.a. CILINDER SISTEM D.O.O.; a.k.a. CILINDER SISTEM D.O.O. ZA PROIZVODNJU I USLUGE), Dr. Mile Budaka 1,
Slavonski Brod 35000, Croatia; 1 Mile Budaka, Slavonski Brod 35000, Croatia; Website http://www.csc-sb.hr; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 050038884 (Croatia); Tax ID No. 27694384517 (Croatia) [IRAN].
CILINDER SISTEM D.O.O. (a.k.a. CILINDER SISTEM D.O.O. ZA PROIZVODNJU I USLUGE; a.k.a. CYLINDER SYSTEM L.T.D.), Dr. Mile Budaka 1,
Slavonski Brod 35000, Croatia; 1 Mile Budaka, Slavonski Brod 35000, Croatia; Website http://www.csc-sb.hr; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 050038884 (Croatia); Tax ID No. 27694384517 (Croatia) [IRAN].
CILINDER SISTEM D.O.O. ZA PROIZVODNJU I USLUGE (a.k.a. CILINDER SISTEM D.O.O.; a.k.a. CYLINDER SYSTEM L.T.D.), Dr. Mile Budaka 1,
Slavonski Brod 35000, Croatia; 1 Mile Budaka, Slavonski Brod 35000, Croatia; Website http://www.csc-sb.hr; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; Registration ID 050038884 (Croatia); Tax ID No. 27694384517 (Croatia) [IRAN].
AMIN INVESTMENT BANK (a.k.a. AMINIB), No. 51 Ghobadiyan Street, Valiasr Street, Tehran 1968917173, Iran; Website http://www.aminib.com;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
AMINIB (a.k.a. AMIN INVESTMENT BANK), No. 51 Ghobadiyan Street, Valiasr Street, Tehran 1968917173, Iran; Website http://www.aminib.com;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
PARDIS INVESTMENT COMPANY (a.k.a. SHERKAT-E SARMAYEGOZARI-E PARDIS), Iran; Unit D4 and C4, 4th Floor, Building 29 Africa, Corner of
25th Street, Africa Boulevard, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 77/83
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SHERKAT-E SARMAYEGOZARI-E PARDIS (a.k.a. PARDIS INVESTMENT COMPANY), Iran; Unit D4 and C4, 4th Floor, Building 29 Africa, Corner of
25th Street, Africa Boulevard, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
MELLAT INSURANCE COMPANY, No. 48, Haghani Street, Vanak Square, Before Jahan-Kodak Cross, Tehran 1517973913, Iran; No. 40, Shahid
Haghani Express Way, Vanak Square, Tehran, Iran; No. 9, Niloofar Street, Sharabyani Avenue, Taavon Boulevard, Shahr-e-Ziba, Tehran, Iran; 72
Hillview Court, Woking, Surrey GU22 7QW, United Kingdom; No. 697 Saeeidi Alley, Crossroads College, Enghelab St., Tehran, Iran; Website
http://www.mellatinsurance.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
IRAN & SHARGH COMPANY (a.k.a. IRAN AND EAST COMPANY; a.k.a. IRAN AND SHARGH COMPANY; a.k.a. IRANOSHARGH COMPANY; a.k.a.
SHERKAT-E IRAN VA SHARGH), 827, North of Seyedkhandan Bridge, Shariati Street, P.O. Box 13185-1445, Tehran 16616, Iran; No. 41, Next to 23rd
Alley, South Gandi St., Vanak Square, Tehran 15179, Iran; Website http://www.iranoshargh.com; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
IRANOSHARGH COMPANY (a.k.a. IRAN & SHARGH COMPANY; a.k.a. IRAN AND EAST COMPANY; a.k.a. IRAN AND SHARGH COMPANY; a.k.a.
SHERKAT-E IRAN VA SHARGH), 827, North of Seyedkhandan Bridge, Shariati Street, P.O. Box 13185-1445, Tehran 16616, Iran; No. 41, Next to 23rd
Alley, South Gandi St., Vanak Square, Tehran 15179, Iran; Website http://www.iranoshargh.com; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
SHERKAT-E IRAN VA SHARGH (a.k.a. IRAN & SHARGH COMPANY; a.k.a. IRAN AND EAST COMPANY; a.k.a. IRAN AND SHARGH COMPANY;
a.k.a. IRANOSHARGH COMPANY), 827, North of Seyedkhandan Bridge, Shariati Street, P.O. Box 13185-1445, Tehran 16616, Iran; No. 41, Next to
23rd Alley, South Gandi St., Vanak Square, Tehran 15179, Iran; Website http://www.iranoshargh.com; Additional Sanctions Information - Not on the
SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
IRAN AND EAST COMPANY (a.k.a. IRAN & SHARGH COMPANY; a.k.a. IRAN AND SHARGH COMPANY; a.k.a. IRANOSHARGH COMPANY; a.k.a.
SHERKAT-E IRAN VA SHARGH), 827, North of Seyedkhandan Bridge, Shariati Street, P.O. Box 13185-1445, Tehran 16616, Iran; No. 41, Next to 23rd
Alley, South Gandi St., Vanak Square, Tehran 15179, Iran; Website http://www.iranoshargh.com; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
IRAN AND SHARGH COMPANY (a.k.a. IRAN & SHARGH COMPANY; a.k.a. IRAN AND EAST COMPANY; a.k.a. IRANOSHARGH COMPANY; a.k.a.
SHERKAT-E IRAN VA SHARGH), 827, North of Seyedkhandan Bridge, Shariati Street, P.O. Box 13185-1445, Tehran 16616, Iran; No. 41, Next to 23rd
Alley, South Gandi St., Vanak Square, Tehran 15179, Iran; Website http://www.iranoshargh.com; Additional Sanctions Information - Not on the SDN
List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
IRAN & SHARGH LEASING COMPANY (a.k.a. IRAN AND EAST LEASING COMPANY; a.k.a. IRAN AND SHARGH LEASING COMPANY; a.k.a.
SHERKAT-E LIZING-E IRAN VA SHARGH), 1st Floor, No. 33, Shahid Atefi Alley, Opposite Mellat Park, Vali-e-Asr Street, Tehran 1967933759, Iran;
Website http://www.isleasingco.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
IRAN AND EAST LEASING COMPANY (a.k.a. IRAN & SHARGH LEASING COMPANY; a.k.a. IRAN AND SHARGH LEASING COMPANY; a.k.a.
SHERKAT-E LIZING-E IRAN VA SHARGH), 1st Floor, No. 33, Shahid Atefi Alley, Opposite Mellat Park, Vali-e-Asr Street, Tehran 1967933759, Iran;
Website http://www.isleasingco.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SHERKAT-E LIZING-E IRAN VA SHARGH (a.k.a. IRAN & SHARGH LEASING COMPANY; a.k.a. IRAN AND EAST LEASING COMPANY; a.k.a. IRAN
AND SHARGH LEASING COMPANY), 1st Floor, No. 33, Shahid Atefi Alley, Opposite Mellat Park, Vali-e-Asr Street, Tehran 1967933759, Iran;
Website http://www.isleasingco.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
IRAN AND SHARGH LEASING COMPANY (a.k.a. IRAN & SHARGH LEASING COMPANY; a.k.a. IRAN AND EAST LEASING COMPANY; a.k.a.
SHERKAT-E LIZING-E IRAN VA SHARGH), 1st Floor, No. 33, Shahid Atefi Alley, Opposite Mellat Park, Vali-e-Asr Street, Tehran 1967933759, Iran;
Website http://www.isleasingco.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons
Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 78/83
TADBIR BROKERAGE COMPANY (a.k.a. SHERKAT-E KARGOZARI-E TADBIRGARAN-E FARDA; a.k.a. TADBIRGARAN FARDA BROKERAGE
COMPANY; a.k.a. TADBIRGARAN-E FARDA BROKERAGE COMPANY; a.k.a. TADBIRGARANE FARDA MERCANTILE EXCHANGE CO.), Unit C2,
2nd Floor, Building No. 29, Corner of 25th Street, After Jahan Koudak, Cross Road Africa Street, Tehran 15179, Iran; Website
http://www.tadbirbroker.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TADBIRGARAN FARDA BROKERAGE COMPANY (a.k.a. SHERKAT-E KARGOZARI-E TADBIRGARAN-E FARDA; a.k.a. TADBIR BROKERAGE
COMPANY; a.k.a. TADBIRGARAN-E FARDA BROKERAGE COMPANY; a.k.a. TADBIRGARANE FARDA MERCANTILE EXCHANGE CO.), Unit C2,
2nd Floor, Building No. 29, Corner of 25th Street, After Jahan Koudak, Cross Road Africa Street, Tehran 15179, Iran; Website
http://www.tadbirbroker.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TADBIRGARANE FARDA MERCANTILE EXCHANGE CO. (a.k.a. SHERKAT-E KARGOZARI-E TADBIRGARAN-E FARDA; a.k.a. TADBIR
BROKERAGE COMPANY; a.k.a. TADBIRGARAN FARDA BROKERAGE COMPANY; a.k.a. TADBIRGARAN-E FARDA BROKERAGE COMPANY),
Unit C2, 2nd Floor, Building No. 29, Corner of 25th Street, After Jahan Koudak, Cross Road Africa Street, Tehran 15179, Iran; Website
http://www.tadbirbroker.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
SHERKAT-E KARGOZARI-E TADBIRGARAN-E FARDA (a.k.a. TADBIR BROKERAGE COMPANY; a.k.a. TADBIRGARAN FARDA BROKERAGE
COMPANY; a.k.a. TADBIRGARAN-E FARDA BROKERAGE COMPANY; a.k.a. TADBIRGARANE FARDA MERCANTILE EXCHANGE CO.), Unit C2,
2nd Floor, Building No. 29, Corner of 25th Street, After Jahan Koudak, Cross Road Africa Street, Tehran 15179, Iran; Website
http://www.tadbirbroker.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TADBIRGARAN-E FARDA BROKERAGE COMPANY (a.k.a. SHERKAT-E KARGOZARI-E TADBIRGARAN-E FARDA; a.k.a. TADBIR BROKERAGE
COMPANY; a.k.a. TADBIRGARAN FARDA BROKERAGE COMPANY; a.k.a. TADBIRGARANE FARDA MERCANTILE EXCHANGE CO.), Unit C2, 2nd
Floor, Building No. 29, Corner of 25th Street, After Jahan Koudak, Cross Road Africa Street, Tehran 15179, Iran; Website http://www.tadbirbroker.com;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
ZARIN RAFSANJAN CEMENT COMPANY (a.k.a. RAFSANJAN CEMENT COMPANY; a.k.a. ZARRIN RAFSANJAN CEMENT COMPANY), 2nd Floor,
No. 67, North Sindokht Street, West Dr. Fatemi Avenue, Tehran 1411953943, Iran; Website http://www.zarrincement.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
RAFSANJAN CEMENT COMPANY (a.k.a. ZARIN RAFSANJAN CEMENT COMPANY; a.k.a. ZARRIN RAFSANJAN CEMENT COMPANY), 2nd Floor,
No. 67, North Sindokht Street, West Dr. Fatemi Avenue, Tehran 1411953943, Iran; Website http://www.zarrincement.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
ZARRIN RAFSANJAN CEMENT COMPANY (a.k.a. RAFSANJAN CEMENT COMPANY; a.k.a. ZARIN RAFSANJAN CEMENT COMPANY), 2nd Floor,
No. 67, North Sindokht Street, West Dr. Fatemi Avenue, Tehran 1411953943, Iran; Website http://www.zarrincement.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
RISHMAK PRODUCTIVE & EXPORTS COMPANY (a.k.a. RISHMAK COMPANY; a.k.a. RISHMAK EXPORT AND MANUFACTURING P.J.S.; a.k.a.
RISHMAK PRODUCTION AND EXPORT COMPANY; a.k.a. RISHMAK PRODUCTIVE AND EXPORTS COMPANY; a.k.a. SHERKAT-E TOLID VA
SADERAT-E RISHMAK), Rishmak Cross Rd., 3rd Km. of Amir Kabir Road, Shiraz 71365, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
RISHMAK COMPANY (a.k.a. RISHMAK EXPORT AND MANUFACTURING P.J.S.; a.k.a. RISHMAK PRODUCTION AND EXPORT COMPANY; a.k.a.
RISHMAK PRODUCTIVE & EXPORTS COMPANY; a.k.a. RISHMAK PRODUCTIVE AND EXPORTS COMPANY; a.k.a. SHERKAT-E TOLID VA
SADERAT-E RISHMAK), Rishmak Cross Rd., 3rd Km. of Amir Kabir Road, Shiraz 71365, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
SHERKAT-E TOLID VA SADERAT-E RISHMAK (a.k.a. RISHMAK COMPANY; a.k.a. RISHMAK EXPORT AND MANUFACTURING P.J.S.; a.k.a.
RISHMAK PRODUCTION AND EXPORT COMPANY; a.k.a. RISHMAK PRODUCTIVE & EXPORTS COMPANY; a.k.a. RISHMAK PRODUCTIVE AND
EXPORTS COMPANY), Rishmak Cross Rd., 3rd Km. of Amir Kabir Road, Shiraz 71365, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 79/83
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
RISHMAK PRODUCTION AND EXPORT COMPANY (a.k.a. RISHMAK COMPANY; a.k.a. RISHMAK EXPORT AND MANUFACTURING P.J.S.; a.k.a.
RISHMAK PRODUCTIVE & EXPORTS COMPANY; a.k.a. RISHMAK PRODUCTIVE AND EXPORTS COMPANY; a.k.a. SHERKAT-E TOLID VA
SADERAT-E RISHMAK), Rishmak Cross Rd., 3rd Km. of Amir Kabir Road, Shiraz 71365, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
RISHMAK EXPORT AND MANUFACTURING P.J.S. (a.k.a. RISHMAK COMPANY; a.k.a. RISHMAK PRODUCTION AND EXPORT COMPANY; a.k.a.
RISHMAK PRODUCTIVE & EXPORTS COMPANY; a.k.a. RISHMAK PRODUCTIVE AND EXPORTS COMPANY; a.k.a. SHERKAT-E TOLID VA
SADERAT-E RISHMAK), Rishmak Cross Rd., 3rd Km. of Amir Kabir Road, Shiraz 71365, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
RISHMAK PRODUCTIVE AND EXPORTS COMPANY (a.k.a. RISHMAK COMPANY; a.k.a. RISHMAK EXPORT AND MANUFACTURING P.J.S.; a.k.a.
RISHMAK PRODUCTION AND EXPORT COMPANY; a.k.a. RISHMAK PRODUCTIVE & EXPORTS COMPANY; a.k.a. SHERKAT-E TOLID VA
SADERAT-E RISHMAK), Rishmak Cross Rd., 3rd Km. of Amir Kabir Road, Shiraz 71365, Iran; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
OMID REY CIVIL & CONSTRUCTION COMPANY (a.k.a. OMID DEVELOPMENT AND CONSTRUCTION; a.k.a. OMID REY CIVIL AND
CONSTRUCTION COMPANY; a.k.a. OMID REY RENOVATION AND DEVELOPMENT CO.); Website http://www.omidrey.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
OMID DEVELOPMENT AND CONSTRUCTION (a.k.a. OMID REY CIVIL & CONSTRUCTION COMPANY; a.k.a. OMID REY CIVIL AND
CONSTRUCTION COMPANY; a.k.a. OMID REY RENOVATION AND DEVELOPMENT CO.); Website http://www.omidrey.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
OMID REY RENOVATION AND DEVELOPMENT CO. (a.k.a. OMID DEVELOPMENT AND CONSTRUCTION; a.k.a. OMID REY CIVIL &
CONSTRUCTION COMPANY; a.k.a. OMID REY CIVIL AND CONSTRUCTION COMPANY); Website http://www.omidrey.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
OMID REY CIVIL AND CONSTRUCTION COMPANY (a.k.a. OMID DEVELOPMENT AND CONSTRUCTION; a.k.a. OMID REY CIVIL &
CONSTRUCTION COMPANY; a.k.a. OMID REY RENOVATION AND DEVELOPMENT CO.); Website http://www.omidrey.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
BEHSAZ KASHANE TEHRAN CONSTRUCTION CO. (a.k.a. BEHSAZ KASHANEH CO.), No. 40, East Street Journal, North Shiraz Street, Sadra
Avenue, Tehran, Iran; Website http://www.behsazco.ir; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
BEHSAZ KASHANEH CO. (a.k.a. BEHSAZ KASHANE TEHRAN CONSTRUCTION CO.), No. 40, East Street Journal, North Shiraz Street, Sadra
Avenue, Tehran, Iran; Website http://www.behsazco.ir; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
ROYAL ARYA CO. (a.k.a. ARIA ROYAL CONSTRUCTION COMPANY), Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
ARIA ROYAL CONSTRUCTION COMPANY (a.k.a. ROYAL ARYA CO.), Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
HORMOZ OIL REFINING COMPANY, Next to the Current Bandar Abbas Refinery, Bandar Abbas City, Iran; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
GHAED BASSIR PETROCHEMICAL PRODUCTS COMPANY (a.k.a. GHAED BASSIR), No. 15, Palizvani (7th) Street, Gandhi (South) Avenue, Tehran
1517655711, Iran; Km 10 of Khomayen Road, Golpayegan, Iran; Website http://www.gbpc.net; Additional Sanctions Information - Not on the SDN List
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 80/83
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
GHAED BASSIR (a.k.a. GHAED BASSIR PETROCHEMICAL PRODUCTS COMPANY), No. 15, Palizvani (7th) Street, Gandhi (South) Avenue, Tehran
1517655711, Iran; Km 10 of Khomayen Road, Golpayegan, Iran; Website http://www.gbpc.net; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
PERSIA OIL & GAS INDUSTRY DEVELOPMENT CO. (a.k.a. PERSIA OIL AND GAS INDUSTRY DEVELOPMENT CO.; a.k.a. TOSE SANAT-E NAFT
VA GAS PERSIA), 7th Floor, No. 346, Mirdamad Avenue, Tehran, Iran; Ground Floor, No. 14, Saba Street, Africa Boulevard, Tehran, Iran; Website
http://www.pogidc.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
TOSE SANAT-E NAFT VA GAS PERSIA (a.k.a. PERSIA OIL & GAS INDUSTRY DEVELOPMENT CO.; a.k.a. PERSIA OIL AND GAS INDUSTRY
DEVELOPMENT CO.), 7th Floor, No. 346, Mirdamad Avenue, Tehran, Iran; Ground Floor, No. 14, Saba Street, Africa Boulevard, Tehran, Iran;
Website http://www.pogidc.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
PERSIA OIL AND GAS INDUSTRY DEVELOPMENT CO. (a.k.a. PERSIA OIL & GAS INDUSTRY DEVELOPMENT CO.; a.k.a. TOSE SANAT-E NAFT
VA GAS PERSIA), 7th Floor, No. 346, Mirdamad Avenue, Tehran, Iran; Ground Floor, No. 14, Saba Street, Africa Boulevard, Tehran, Iran; Website
http://www.pogidc.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue
to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
PARS OIL CO. (a.k.a. PARS OIL; a.k.a. SHERKAT NAFT PARS SAHAMI AAM), Iran; No. 346, Pars Oil Company Building, Modarres Highway, East
Mirdamad Boulevard, Tehran 1549944511, Iran; Postal Box 14155-1473, Tehran 159944511, Iran; Website http://www.parsoilco.com; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
PARS OIL (a.k.a. PARS OIL CO.; a.k.a. SHERKAT NAFT PARS SAHAMI AAM), Iran; No. 346, Pars Oil Company Building, Modarres Highway, East
Mirdamad Boulevard, Tehran 1549944511, Iran; Postal Box 14155-1473, Tehran 159944511, Iran; Website http://www.parsoilco.com; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SHERKAT NAFT PARS SAHAMI AAM (a.k.a. PARS OIL; a.k.a. PARS OIL CO.), Iran; No. 346, Pars Oil Company Building, Modarres Highway, East
Mirdamad Boulevard, Tehran 1549944511, Iran; Postal Box 14155-1473, Tehran 159944511, Iran; Website http://www.parsoilco.com; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
COMMERCIAL PARS OIL CO., 9th Floor, No. 346, Mirdamad Avenue, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
MARJAN PETROCHEMICAL COMPANY (a.k.a. MARJAN METHANOL COMPANY), Ground Floor, No. 39, Meftah/Garmsar West Alley, Shiraz (South)
Street, Molla Sadra Avenue, Tehran, Iran; Post Office Box 19935-561, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
MARJAN METHANOL COMPANY (a.k.a. MARJAN PETROCHEMICAL COMPANY), Ground Floor, No. 39, Meftah/Garmsar West Alley, Shiraz (South)
Street, Molla Sadra Avenue, Tehran, Iran; Post Office Box 19935-561, Tehran, Iran; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
GHADIR INVESTMENT COMPANY, 341 West Mirdamad Boulevard, Tehran, Iran; P.O. Box 19696, Tehran, Iran; Website http://www.ghadir-invest.com;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SADAF PETROCHEMICAL ASSALUYEH COMPANY (a.k.a. SADAF ASALUYEH CO.; a.k.a. SADAF CHEMICAL ASALUYEH COMPANY; a.k.a.
SADAF PETROCHEMICAL ASSALUYEH INVESTMENT SERVICE), Assaluyeh, Iran; South Pars Special Economy/Energy Zone, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SADAF ASALUYEH CO. (a.k.a. SADAF CHEMICAL ASALUYEH COMPANY; a.k.a. SADAF PETROCHEMICAL ASSALUYEH COMPANY; a.k.a.
SADAF PETROCHEMICAL ASSALUYEH INVESTMENT SERVICE), Assaluyeh, Iran; South Pars Special Economy/Energy Zone, Iran; Additional
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 81/83
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SADAF CHEMICAL ASALUYEH COMPANY (a.k.a. SADAF ASALUYEH CO.; a.k.a. SADAF PETROCHEMICAL ASSALUYEH COMPANY; a.k.a.
SADAF PETROCHEMICAL ASSALUYEH INVESTMENT SERVICE), Assaluyeh, Iran; South Pars Special Economy/Energy Zone, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SADAF PETROCHEMICAL ASSALUYEH INVESTMENT SERVICE (a.k.a. SADAF ASALUYEH CO.; a.k.a. SADAF CHEMICAL ASALUYEH
COMPANY; a.k.a. SADAF PETROCHEMICAL ASSALUYEH COMPANY), Assaluyeh, Iran; South Pars Special Economy/Energy Zone, Iran; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
POLYNAR COMPANY, No. 58, St. 14, Qanbarzadeh Avenue, Resalat Highway, Tehran, Iran; Website http://www.polynar.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
ONE CLASS PROPERTIES (PTY) LTD. (a.k.a. ONE CLASS INCORPORATED), Cape Town, South Africa; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
ONE CLASS INCORPORATED (a.k.a. ONE CLASS PROPERTIES (PTY) LTD.), Cape Town, South Africa; Additional Sanctions Information - Not on
the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person
Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
ONE VISION INVESTMENTS 5 (PTY) LTD. (a.k.a. ONE VISION 5), 3rd Floor, Tygervalley Chambers, Bellville, Cape Town 7530, South Africa; Canal
Walk, P.O. Box 17, Century City, Milnerton 7446, South Africa; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 2002/022757/07
(South Africa) [IRAN].
ONE VISION 5 (a.k.a. ONE VISION INVESTMENTS 5 (PTY) LTD.), 3rd Floor, Tygervalley Chambers, Bellville, Cape Town 7530, South Africa; Canal
Walk, P.O. Box 17, Century City, Milnerton 7446, South Africa; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Registration ID 2002/022757/07
(South Africa) [IRAN].
PARS MCS (a.k.a. PARS MCS CO.; a.k.a. PARS MCS COMPANY), 2nd Floor, No. 4, Sasan Dead End, Afriqa Avenue, After Esfandiar, Crossroads,
Tehran, Iran; No. 5 Sasan Alley, Atefi Sharghi St., Afrigha Boulevard, Tehran, Iran; Oshtorjan Industrial Zone, Zob-e Ahan Highway, Isafahan, Iran;
Website http://www.parsmcs.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
PARS MCS COMPANY (a.k.a. PARS MCS; a.k.a. PARS MCS CO.), 2nd Floor, No. 4, Sasan Dead End, Afriqa Avenue, After Esfandiar, Crossroads,
Tehran, Iran; No. 5 Sasan Alley, Atefi Sharghi St., Afrigha Boulevard, Tehran, Iran; Oshtorjan Industrial Zone, Zob-e Ahan Highway, Isafahan, Iran;
Website http://www.parsmcs.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
PARS MCS CO. (a.k.a. PARS MCS; a.k.a. PARS MCS COMPANY), 2nd Floor, No. 4, Sasan Dead End, Afriqa Avenue, After Esfandiar, Crossroads,
Tehran, Iran; No. 5 Sasan Alley, Atefi Sharghi St., Afrigha Boulevard, Tehran, Iran; Oshtorjan Industrial Zone, Zob-e Ahan Highway, Isafahan, Iran;
Website http://www.parsmcs.com; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must
Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
OIL INDUSTRY INVESTMENT COMPANY (a.k.a. "O.I.I.C."), No. 83, Sepahbod Gharani Street, Tehran, Iran; Website http://www.oiic-ir.com; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
"O.I.I.C." (a.k.a. OIL INDUSTRY INVESTMENT COMPANY), No. 83, Sepahbod Gharani Street, Tehran, Iran; Website http://www.oiic-ir.com; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
REY NIRU ENGINEERING COMPANY (a.k.a. REY NIROO ENGINEERING COMPANY); Website http://www.reyniroo.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 82/83
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
REY NIROO ENGINEERING COMPANY (a.k.a. REY NIRU ENGINEERING COMPANY); Website http://www.reyniroo.com; Additional Sanctions
Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in
Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf [IRAN].
SWISS MANAGEMENT SERVICES SARL, 28C, Route de Denges, Lonay 1027, Switzerland; Additional Sanctions Information - Not on the SDN List
and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to
Executive Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…
[IRAN].
SEYYEDI, Seyed Nasser Mohammad; DOB 21 Apr 1963; citizen Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to
Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599;
For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Passport B14354139
(Iran); alt. Passport L18507193 (Iran); alt. Passport X95321252 (Iran); Managing Director, Sima General Trading (individual) [IRAN].
KASB INTERNATIONAL LLC (a.k.a. FIRST FURAT TRADING LLC), 10th Floor, Citi Bank Building, Oud Metha Road, Oud Metha, Dubai, United Arab
Emirates; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone Number: (971) (4) (3248000) [IRAN].
FIRST FURAT TRADING LLC (a.k.a. KASB INTERNATIONAL LLC), 10th Floor, Citi Bank Building, Oud Metha Road, Oud Metha, Dubai, United Arab
Emirates; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Telephone Number: (971) (4) (3248000) [IRAN].
PETRO ROYAL FZE, United Arab Emirates; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
AA ENERGY FZCO, United Arab Emirates; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j… [IRAN].
PARSAEI, Reza; DOB 09 Aug 1963; citizen Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S.
Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information,
please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Director, NIOC International Affairs (London)
Ltd. (individual) [IRAN].
TABATABAEI, Seyyed Mohammad Ali Khatibi; DOB 27 Sep 1955; citizen Iran; Additional Sanctions Information - Not on the SDN List and Not Subject
to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order
13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Director, NIOC
International Affairs (London) Ltd.; Director of International Affairs, NIOC (individual) [IRAN].
ZIRACCHIAN ZADEH, Mahmoud; DOB 24 Jul 1959; citizen Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Director, Iranian Oil Company
(U.K.) Ltd. (individual) [IRAN].
MOHADDES, Seyed Mahmoud; DOB 07 Jun 1957; citizen Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary
Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more
information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Managing Director, Iranian Oil
Company (U.K.) Ltd. (individual) [IRAN].
MOINIE, Mohammad; DOB 04 Jan 1956; POB Brojerd, Iran; citizen United Kingdom; Additional Sanctions Information - Not on the SDN List and Not
Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive
Order 13599; For more information, please see: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; Passport
301762718 (United Kingdom); Commercial Director, Naftiran Intertrade Company Sarl (individual) [IRAN].
KHAVARMIANEH BANK (a.k.a. MIDDLE EAST BANK), No. 22, Second Floor Sabounchi St., Shahid Beheshti Ave., Tehran, Iran; SWIFT/BIC
KHMIIRTH; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; All offices worldwide [IRAN].
MIDDLE EAST BANK (a.k.a. KHAVARMIANEH BANK), No. 22, Second Floor Sabounchi St., Shahid Beheshti Ave., Tehran, Iran; SWIFT/BIC
KHMIIRTH; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; All offices worldwide [IRAN].
GHAVAMIN BANK (a.k.a. "GHAVAMIN FINANCIAL & CREDIT INS."), No. 252 Milad Tower, Beginning of Africa Blvd., Argentina Sq, Tehran, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
Annex 152
8/5/2019 Publication of Updates to OFAC’s Specially Designated Nationals and Blocked Persons List and 13599 List Removals
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pag… 83/83
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; All offices worldwide [IRAN].
"GHAVAMIN FINANCIAL & CREDIT INS." (a.k.a. GHAVAMIN BANK), No. 252 Milad Tower, Beginning of Africa Blvd., Argentina Sq, Tehran, Iran;
Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property
and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; All offices worldwide [IRAN].
GHARZOLHASANEH RESALAT BANK, Biside the No. 1 Baghestan Alley, Saadat Abad Ave., Kaj Sq., Tehran, Iran; Additional Sanctions Information -
Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests in Property of this
Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; All offices worldwide [IRAN].
KISH INTERNATIONAL BANK (a.k.a. KISH INTERNATIONAL BANK OFFSHORE COMPANY PJS), NBO-9, Andisheh Blvd, Sanayi Street , Kish
Island, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; All offices worldwide [IRAN].
KISH INTERNATIONAL BANK OFFSHORE COMPANY PJS (a.k.a. KISH INTERNATIONAL BANK), NBO-9, Andisheh Blvd, Sanayi Street , Kish
Island, Iran; Additional Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the
Property and Interests in Property of this Person Pursuant to Executive Order 13599; For more information, please see:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/j…; All offices worldwide [IRAN].
KAFOLATBANK (a.k.a. CJSC KAFOLATBANK), Apartment 4/1, Academics Rajabovs Street, Dushanbe, Tajikistan; SWIFT/BIC KACJTJ22; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; All offices worldwide [IRAN].
CJSC KAFOLATBANK (a.k.a. KAFOLATBANK), Apartment 4/1, Academics Rajabovs Street, Dushanbe, Tajikistan; SWIFT/BIC KACJTJ22; Additional
Sanctions Information - Not on the SDN List and Not Subject to Secondary Sanctions; U.S. Persons Must Continue to Block the Property and Interests
in Property of this Person Pursuant to Executive Order 13599; For more information, please see: https://www.treasury.gov/resourcecenter/
sanctions/Programs/Documents/jcpoa_faqs.pdf; All offices worldwide [IRAN].
Annex 152
Annex 153
Annex 153
Annex 153
Annex 153
This content downloaded from 169.252.4.21 on Mon, 12 Aug 2019 21:06:37 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:50:13 UTC
All use subject to https://about.jstor.org/terms Annex 156
ARCHIV
DES VÖLKERRECHTS
Herausgegeben von
Dr. Hans- Jürgen Schlochauer Dr. Dr. Hans Wehberg
Professor an der Universität Frankfurt am Main Professor am Institut Universitaire
Membre de la Cour Permanente d'Arbitrage de Hautes Etudes Internationales, Genf
Generalsekretär des Institut de Droit international
Dr. Walter Schätzel t
Professor an der Universität Bonn
Associé de l'Institut de Droit international
9. Band • 3. Heft
September 1961
ARIIBUS
I I O- I
I961
J.C.B. MOHR (PAUL SIEBECK) TÜBINGEN
This content downloaded from 169.252.4.21 on Mon, 12 Aug 2019 21:10:35 UTC
All use subject to https://about.jstor.org/terms
Annex 157
ABHANDLUNGEN
United States Protection of Private Foreign Investment
throughTreaties of Friendship, Commerce and Navigation
H. P. CONNELL, B. A., LL. M.
Lecturer in Laws, London
I. Introduction
The post- World War II era has been characterized by the struggle improve economic conditions through the strengthening of the European economy and the advancement of underdeveloped areas. relatively recently, the United States was the only country which capital in the quantities needed for this economic reconstruction and consequently, the greatest part of the capital expended these purposes since World War II was American. The United States policy has been geared to this recovery and development 1).
Today, with its industrial potential restored, its currencies economy sound, Western Europe's recovery is completed. A new balance of power has been created, and European countries need no rely solely on United States capital for economic development. With once again on its feet, and the West challenged to an economic war Soviets, the emphasis has shifted from Europe to the underdeveloped of the world. While the United States is still the country with capital available for export, the amount of capital needed for development throughout the world is too great to be supplied solely United States Government finance. Therefore, the Government endeavored to stimulate private American investment in underdeveloped
countries.
To facilitate the flow of capital from the United States to these the Government has established agencies 2) and cooperated in the See Foreign Assistance Act of 1948, 61 Statutes 137, as amended, States Code § 1501 (Supplement 1952) (Marshall Plan); and Act for International
Development, 64 Statutes 204 (1950), 22 United States Code § 1557a (1952) (Point Four Program).
2) Export-Import Bank Act 1945, 59 Statutes 527, as amended, 12 United Code § 635 (a) (1952); Foreign Assistance Act of 1948, note 1 supra, through the U.S. Government guarantees investors against certain risks; and This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment 257
ment of international organizations8) to foster investment. In addition to
the agencies which finance and guarantee foreign investments, the Government
has attempted to create a favorable investment climate by providing
tax incentives and informational and technical assistance programs4).
Although there are many reasons cited for the lack of private foreign
investment5), many of them reflect one or the other of the two primary
concerns of a private investor, prospective profit and risk. The Government
has endeavored to stimulate investment by directly influencing these factors
to create a favorable investment climate. For example, the purpose of tax
incentives is to enhance prospective profits, whereas treaties of friendship,
commerce and navigation and government guaranties are meant to reduce
the risk involved. However, the fact remains that the results of the United
States' efforts to stimulate private foreign investment have been unimpressive6).
Security Act of 1957, § 202 71 Statutes 357, 22 United States Code § 1872 (Supplement
1957), which created the Development Loan Fund.
3) International Bank tor Reconstruction and Development, (world JBank); the
International Finance Corporation; and more recently, The International Development
Association; The Inter- American Development Bank; The Development Assistance
Group; and the United Nations Special Fund. See S hon field, The Attack
on World Poverty, i960; Miller, The ECA Guaranties and Stimulation of Foreign
Private Investment in Georgetown Law Journal Vol. 39 (1950) p. 1; United States
Agencies and International Organizations Which Foster Private American Investment
Abroad (Note) in Harvard Law Review Vol. 71 (1958) p. 1102; Government
Guaranties of Foreign Investment (Note) in Harvard Law Review Vol. 66
(1953) P- 514-
4) See Surrey, Current Issues in the Taxation ot Corporate foreign Investment
in Columbia Law Review Vol. 56 (1956) p. 815; United States Agencies and International
Organizations Which Foster Private American Investment Abroad (Note)
supra note 3 ; Tax Incentives to Investment Abroad (Note) in Stanford Law Review
Vol.8 (1955) p. 77.
5) See U.S. Department ot Commerce, factors Limiting U.î>. Investment Abroad
Pts. 1 & 2 (1953-1954): "The complex reasons which underlie this shortage of private
investment include: the competing attraction of domestic investments; the
danger of war; possible political or economic instability in the country in which
the investment is to be located; fear of such arbitary action by the host government
as confiscation, expropriation or discriminatory tax laws; legal restrictions on the
type of investment or the degree of participation available to foreigners; and the
risk of inadequate profits caused by limited markets, high production costs, unskilled
labor, or lack of basic economic facilities." See also Barlow and Wender, Foreign
Investment and Taxation, 1955, p. 77, no, 143; Wilcox, A Charter for World
Trade, 1949, p. 142-145; Brandon, Legal Aspects of Private Foreign Investment in
Federal Bar Journal Vol.18 (1958) p. 298, 298-302; Domke, The Settlement of
International Investment Disputes in Business Lawyer Vol. 12 (1957) p. 264; Littell,
Obstructions to Private Investment Abroad in Virginia Law Review Vol. 36 (1950)
p. 873, 876; Foreign Trade and Development (Symposium) in Ohio State Law
Journal Vol. 17 (1956) p. 254, 254-266.
6) Rubin, Private Foreign Investment, 1956, p. 74; Symposium, supra note 5,
at p. 256; United States Agencies and International Organizations Which Foster
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
258 H.P.Connell
Of the many reasons cited for the lack has had a greater impact than the nationalizations which have become rather commonplace international society. The problem created the conflict between two basic principles, over all that is within its territory, and property belonging to nationals of another Under the generally accepted doctrine entails the duty to pay prompt, adequate, However, the trend has been to accept to less than full satisfaction. This has been is better than nothing, or that long, drawn-out payment in which there be met9). In some cases, that any compensation probably due primarily to the fact that situated outside of the nationalizing State.
Some U. S. nationals whose foreign have obtained relief through U. S. legislation Private American Investment Abroad, supra of Foreign Investment, supra note Barlow and Wender* od. cit. suora note *. at o.a. ii„ h. i« and 21.
7) ownership. the International 2nd Compensation Quarterly Abroad 8) Law, articles the question in property 9) Interests p. 1, 12.
10) See Kuhn, Nationalization of Foreign- Armed Property in its Impact on
International Law in American Journal of International Law Vol. 45 (195 1) p. 709,
710; Rode, The International Claims Commission of the United States in American
Journal of International Law Vol.47 (1953) p. 61 j, 617-621.
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment 259
Settlement Act of 1949 created the International Claims Commission, the
purpose of which was to adjudicate and give final decision with respect to
claims of the U. S. or of its nationals arising out of the Yugoslav Claims
Agreement of 1948 or, from claims arising out of future claims agreements
between the United States and foreign countries 11). Similarly, after the Communist
regimes in Hungary, Rumania, and Bulgaria nationalized property
belonging to U. S. nationals in violation of treaties, the United States in
1955 passed legislation designed to compensate disenfranchised U.S. nationals12).
That the United States was holding gold belonging to the Yugoslav
Government amou ting to 46 800 000 dollars at the time of the Yugoslav
nationalization was a fortuitous circumstance18). Furthermore, that some
American claimants whose property was nationalized shared in the distribution
of Italian and Eastern European assets which were blocked in the
United States under wartime conditions was another fortuitous situation14).
However, such good fortune may not be the case in the future when foreign
investment controversies arise 15).
Under these conditions is it not surprising that United States private
investors have not responded to the call for foreign investment. Nor is it
strange that there have been a number of proposals made for an International
Investment Code, not only by capital exporting interests, but also by
capital importing interests who are in need of capital and are willing to
give protection to the foreign investor 18).
To provide much needed protection to the American foreign investor, the
United States has embarked on a treaty program by which protection of
private property owned by United States nationals and situated in foreign
countries is provided in bilateral treaties of friendship, commerce and navigation17).
It is the purpose of this paper to examine these treaties to determine
to what extent they provide protection to foreign property owners.
11) Kuhn, supra note 10; Rode, supra note 10.
12) Rubin, op. cit. supra note 6> at p. 95-96.
13) See id. at p. 93; Domke, supra note 5, at p. 269.
14) Domke, supra note 5. at p. 269. lhe same is true in regard to the Egyptian
assets blocked in the Bank of England after the nationalization of the Suez Maritime
Canal Company.
15) Id. at p. 269.
16) See W. Fnedmann, Legal Aspects or Foreign Investment, 1959, p. 701 ; M tiler,
Protection of Private Foreign Investment by Multilateral Convention in American
Journal of International Law Vol.53 (1959) p. 371; Schwarzenberger, The Abs-
Shawcross Draft Convention on Investments Abroad in Current Legal Problems
Vol. 14 (1961) p. 213.
17) See F riedmann, op. cit. supra note 16, at p. 705; Walker, Treaties for the
Encouragement and Protection of Foreign Investment: Present U.S. Practice in
American Journal of Comparative Law Vol. 5 (1956) p. 229. Since World War II
the United States has negotiated commercial treaties with: China (1946), 63 Statu-
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
26o H. P. Connell
IL The Development of Commercial Treaties
The treaties signed by England and the other European powers of the
15 th and 1 6th centuries are of historical importance because they contain
the principles, in embryo form, which underlie all commercial treaties18).
The principles are freedom of commerce, and equality of treatment of commercial
nations, and are found in the early treaty provisions which provided
for the freedom of entry and visit by foreign merchants in cities and ports
of states19). These principles developed more fully in European treaties of
commerce during the 17th and the beginning of the 18th centuries20). This
period is referred to by Nolde in connection with the development of treaties
of commerce as "la grande époque dans leur évolution"21).
The 19th and 20th centuries witnessed the further development of commercial
treaties. The protection originally granted to the person and property
of foreign merchants was extended to all foreign nationals, and the
extensive use of the most-favored-nation clause in commercial treaties caused
such protection to be greatly extended throughout the world22). Whereas
early commercial treaties contained general provisions in broad language,
present-day commercial treaties are composed of numerous provisions
covering in detail the many facets of 20th century international commerce.
Early commercial treaties were concerned primarily with the protection
tes 1299, 2j United Nations Treaty Series 69; Italy (1948), 63 Statute (2) 2255,
79 United Nations Treaty Series 171; Ireland (1950), 1 United States Treaties 785,
206 United Nations Treaty Series 269; Greece (195 1), 5 United States Treaties
1829, 224 United Nations Treaty Series 279; Israel (195 1), 5 United States
Treaties 550, 219 United Nations Treaty Series 237; Ethiopia (195 1), 4 United
States Treaties 2134, 206 United Nations Treaty Series 41; Japan (1953), 4 United
States Treaties 2063, 206 United Nations Treaty Series 143; Federal Republic of
Germany (1954), 7 United States Treaties 1839, Treaties and Other International
Acts Series No. 3593; Iran (1955), 8 United States Treaties 899, Treaties and Other
International Acts Series No. 3853; Netherlands (1956), 8 United States Treaties
2043, 285 United Nations Treaty Series 231; Korea (1956), 8 United States Treaties
2217, Treaties and Other International Acts Series No. 3947; Nicaragua (1956),
Treaties and Other International Acts Series No. 4026; Pakistan (1959), Treaties
and Other International Acts Series No. 4683; France (1959), Treaties and Other
International Acts Series No. 4625. The United States has also concluded commercial
treaties with Columbia, Denmark, Haiti, and Uruguay which, for various
reasons, are not in effect. Supplementary agreements have been concluded with
Finland (1950), 4 United States Treaties 2047, 92 United Nations Treaty Series 179,
and Italy. The latter agreement is not yet in force. As to treaties of commerce of
the United States generally cf. Wilson, United States Commercial Treaties and
International Law, i960.
18) Nolde, Droit et Technique des Traités de Commerce in Recueil des Cours
Vol. 3 (1924, II) p. 291, at p. 301-304.
19) Ibid.
20) Id. at p. 305.
21Ì Ibid.
22) Id. at p. 363; S cbwar zenberger, op. cit. supra note 8, at p. 207.
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment 261
of the rights and privileges of persons. Recipients of rights under these
treaties were usually identified by sudi terms as "citizen", "subject", "inhabitants",
or "nationals"28). There is no mention of corporations, companies,
partnerships or other legal entities in U.S. commercial treaties until
the 191 1 treaty with Japan24). Since then, provisions for such legal entities
have multiplied to the point where they aré, in present-day treaties, dealt
with to a degree comparable to that of natural persons25).
Provisions for legal entities are just one of many provisions which,
although absent from earlier treaties, are an integral part of present-day
treaties. Recent treaties of friendship, commerce and navigation contain
provisions for such things as: piercing the corporate veil; access-to-courts
envisioning administrative tribunals and agencies, as well as legal aid, security
for costs and judgment; public corporations and state trading; nationalization
and compensation; exchange restrictions in light of the International
Monetary Fund; and international trade in light of The General
Agreement on Tariffs and Trade.
Just as one can see the change in treaty provisions to include legal entities
as the need arose, so also the metamorphosis of the access-to-courts provisions
in earlier treaties can be traced from the embryonic stage of a general
principle in broad language26), to the stage of development at which we
find it today, including within its perview administrative tribunals and
agencies, legal aid and costs27). Some provisions found in present-day treaties
are new and have but a short history, while others are old and have a
long and interesting history spanning several centuries. However, all have
been shaped by a myriad of influences and have taken their present form
according to the exigencies of the day28).
The provisions pertaining to the protection of private property are no
exception to this phenomenon. They too are a product of the forces of history
which determined their present structure. There is no need to go into detail
23) Herod, Favored Nation Treatment, 1901, p. 36; Walker, Provisions on Companies
in U.S. Commercial Treaties in American Journal of International Law
Vol. 50 (1956) p. 373, 377.
24) Walker, supra note 23, at p. 373.
25) Id. at p. 380.
26) See Nolde, supra note 18, at p. 308, for an example of an 18th century
access-to-courts provision.
27) See, e.g., Treaty of friendship, commerce and navigation with Israel (195 1),
5 United States Treaties 550, 219 United Nations Treaty Series 237, Art. V and
Protocol, par. 5. See generally Wilson, Access- to-Courts Provisions in U.S. Commercial
Treaties in American Journal of International Law Vol.47 (1953) p. 20.
28) See Nolde, supra note 18, at p. 325. when commenting on the torty- three
commercial treaties in force in Germany in 191 1, Nolde states: "Chacun de ces
traités, appartenant à des époques si différentes, porte le style de son temps, fait
valoir les préoccupations qui dominaient au moment de sa conclusion et répond aux
méthodes de réglementation qui étaient alors acceptés."
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
262 H. P. Connell
concerning the effects created by in the Union of Soviet Socialist Republics countries of eastern Europe following Iran and Egypt. Nor is there need circumstances of Europe following in many underdeveloped countries the above circumstances, and the political the United States found itself, and flow of private capital from the United one can see some of the forces friendship, commerce and navigation.
In the case of protection of private of merely changing the structure of to one more precisely detailed great and consequent changes so many has been changed. Although they commerce and navigation and contain emphasis has been changed to such investment treaties 29).
III. The Standards of International Economic Law
Although the treaties of friendship, commerce and navigation content and it is not feasible to pick one as a model for analyzation, are homogeneous threads woven through all of them. These standards of international economic law 80) which are indigenous treaties, and which form a basis for examination and Early commercial treaties contained provisions which reflected, form, the principles of freedom of commerce and equality of commercial nations. As international commerce expanded the provisions which, though based on these principles, provided and modifications. Thus, from the need and consequent creation which provided for preferential treatment and which were excerptions principle of equality, developed the preferential treatment standard.
Similarly, early treaties often provided, on the basis of reciprocity subject to local laws, that the nationals of each country were 29) See Walker, supra note 17, at p. 239-240, 244.
30) The standards of international economic law are: minimum law; national treatment standard; most-favored-nation treatment standard; standard of the open door; standard of the standard of preferential treatment. See Schwarzenberger, The Standards of International Law in International Law Quarterly p. 402, 409-411; id. The Frontiers of International Law, Chapter 9, This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment 263
right to live in the other country, to buy and sell in the foreign markets,
and to be secure in person and property81). From these provisions developed
the standard of national treatment.
A most-favored-nation clause appeared for the first time in its modern
form in the treaty between England and Bretagne in i48632). This clause
was conceived in its unconditional form, and it was not until the treaty between
the United States and France in 1778, the first treaty concluded by
the United States, that a most-favored-nation clause appeared in its conditional
form83). From provisions of this nature developed the most- favorednation
standard.
It is beyond the scope of this paper to trace the development of each of
the standards of international economic law. However, essential to any
examination of commercial treaties is an understanding of the purposes and
functionings of these standards. To illustrate the importance of these standards
as fundamental constituents of all treaties of friendship, commerce
and navigation, we shall examine provisions concerning access-to-courts,
search and seizure, ownership of real property, patents, trademarks and
trade names, and taxes, in treaties of friendship, commerce and navigation
signed on behalf of the United States with China, Italy, Ireland, Greece,
Israel, and the Netherlands 34).
With the aid of the charts, appended, it is possible to see the international
standards which have been used in each of the treaties to cover the subjects
listed across the top of the chart. The basic standards in all the treaties are
national treatment and most-favordd-nation treatment35). These standards
are used both in their absolute and modified forms, as well as in combina-
31) Herod, op. cit. supra note 23, at p. 1; Nolde, op. cit. supra note 18, at
p. 301-304.
32) Nolde, op. cit. supra note 18, at p. 303-304.
33) Id. at 312. It is important to distinguish between conditional and unconditional
most-favored-nation treatment. Conditional most-favored-nation treatment
is not most-favored-nation treatment with exceptions. See Hawkins, Commercial
Treaties and Agreements - Principles and Practice, 195 1, p. 67; Herod, op. cit.
supra note 23, at p. 6; Nolde, supra note 18, at p. 422-424.
34) These six treaties were chosen for purposes of illustration because: they are
of relatively recent origin; they provide a good cross section due to diversity of
such things as geographical location, cultural background, degree of economic advancement
and political circumstance; and, for purposes of expediency, they are
readily available in the United Nations Treaties Series. In regard to the absence of
a treaty with a South American country, see text at note 47 infra and authorities
therein. The below mentioned charts are reprinted infra at p. 302 et seq.
35) AU of the post- World War II treaties of friendship, commerce and navigation
state in their preambles that they are based in general upon the principles ot
national and unconditional most- favored-nation treatment, except China (1946),
Ethiopia (195 1), and Iran (1955). The Iranian treaty provides that the treaty is to
be "on the basis of reciprocal equality of treatment".
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
264 H. P. Connell
tion with each other and other standards86). the standards are mutually exclusive in their be harmonized by a grant of exemptions. For standard is incompatible with the An examination of the chart will reveal the extensive interplay between
the various standards created by the modifications and combinations of the
standards. In several of the treaties, where the possibility of prejudicial
treatment was foreseeable through individual state legislation concerning the
right to hold real property in the states of the United States, the possible
absence of reciprocity was averted by the insertion of the standard of
mutuality 88). Where a problem arose concerning the conflict of a treaty provision
and national law dealing with companies, the United States accepted a
provision granting national treatment subject to "screening"89) by the national
law40). Other provisions contain standards modified by the acknowledgement
of the State's overriding obligations to such international institutions
as the International Monetary Fund and the General Agreement on
Tariffs and Trade41). All of these provisions reflect the flexibility of the
treaty provisions as a whole, and in particular, the many combinations and
36) It is important to distinguish between standards as abstract principles, and
specific standards in treaties which, although based on the principle of a particular
standard, are subject to the modifications contained in the treaty.
37) Schwarzenberger, supra note 29, at p. 410-41 1. Following the Peace Treaty
of Utrecht (171 3), the Parliament of England rejected the famous commercial treaty
with France because Article 8 of the treaty contained a most- favored-nation clause
which would have conflicted with a treaty with Portugal under which Portugese
wines received preferential treatment in exchange for the admittance of English
textiles into Portugal. After nearly a century of conventionless commercial relations
due to the English rejection of the commercial treaty in 171 3, a new treaty of
commerce was concluded in 1786 which contained an explicit exception to the
rights accorded Portugal under the Methuen Treaty (1703). Nolde, supra note 18,
at p. 308 and 312. See also Lecky, A History of England in the Eighteenth Century,
Vol. 1. 2nd edition. 1879. p. 142-145.
38) Treaty of friendship, commerce and navigation with China (1946), 63 Statutes
1299, 25 United Nations Treaty Series 69, Art. VIII, par. 1; Treaty of friendship,
commerce and navigation with Italy (1948), 63 Statute (2) 2255, 79 United
Nations Treaty Series 171, Art. VII, par. 1; Treaty of friendship, commerce and
navigation with Israel (195 1), 5 United States Treaties 550, 237, Art. IX, par. 2.
39) See Friedmann, op. cit. supra note 16, at p. 749; Walker, supra note 17, at
p. 242, 246.
40) Treaty of friendship, commerce and navigation with Ireland (1950), 1 United
States Treaties 785, 206 United Nations Treaty Series 269, Art. VI.
41) See, e.g., Treaty of friendship, commerce and navigation with the Netherlands
(1956), 8 United States Treaties 2043, 285 United Nations Treaty Series 231,
Art. XII, par. 2, and Art. XXII, par. 4. Arrangements under the Common Market
are provided for in the Exchange of Notes ratifying the treaty.
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment 265
permutations of the standards of international economic law which can be
created to fit the particular needs of the contracting parties.
The above indicates generally the development of commercial treaties,
and the importance and functions of the standards of international economic
law. We shall now examine the provisions which deal specifically with the
protection of property to determine the degree of protection they afford.
IV. Property Protection Provisions in Post-World
War I Commercial Treaties
Shortly after World War I the United States negotiated a series of treaties. Beginning with the treaty between the United States Germany in 1923, and ending with the treaty between the United and Liberia in 1938, all the commercial treaties signed on behalf United States contained a standard provision pertaining to the protection
of property in the territories of the contracting parties42). The standard
provision provided: "The nationals of each High Contracting Party receive within the territories of the other, upon submitting to conditions
imposed upon its nationals, the most constant protection for their and property, and shall enjoy in this respect the degree of protection is required by international law. Their property shall not be taken due process of law and without payment of just compensation48)."
A number of things should be noted with regard to the above provision.
The first is that the provision accords protection to "nationals", and no specific reference to companies. Companies were not specifically mentioned
in this respect in United States commercial treaties until the treaty China in 1946 44). It has been inferred that companies may be impliedly
covered by the term "national"45). However, the generally accepted 42) Wilson, The International Law Standard in Treaties of the United 1953» P- 9*-
43) This provision appears in treaties with: Germany, 1923 (44 Statute 2132); Hungary, 1925 (44 ibid. [3] 2441); Estonia, 1925 (44 ibid. [3] 2379); Salvador, 1926 (46 ibid. [2] 2817); Honduras, 1927 (45 ibid. [2] 2618); 1928 (45 ibid. [2] 2641); Norway, 1928 (47 ibid. [2] 213$); Austria, 1928 [2] 1876); Poland, 193 1 (48 ibid. [2] 1507); Danzig, 1934 (48 ibid. Finland, 1934 (49 ibid. [2] 2659); Siam, 1937 (53 ibid. [3] 1731); Liberia, (54 ibid. [2] 1739). The provision is slightly varied in the treaty with Siam. op. cit. supra note 42, at p. 92-93. For the above treaties which are still see Treaties in Force, U. S. Department of State Publication.
44) Treaty of friendship, commerce and navigation with China (1946) 1299, 25 United Nations Treaty Series 69, Art. VI, par. 2; Walker, supra 23, at p. 380.
45) Wilson, op. cit. supra note 42, at p. 20 note 76. When referring to the property-
protection clause in pre- World War II treaties Wilson states: "companies are
not mentioned . . . separately from nationals." When referring to post- World War II
property protection provisions he states: "... companies are covered by specific
18 ArdiVR 9/3
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
i66 H. P. Connell
is that in general companies are not except where expressly so provided46).
The next question concerns the effect to conditions imposed upon its nationals have put forth the thesis that national claimed by foreign nationals under it is generally accepted today standards binding all nations regardless chooses to apply to its own nationals48). national treatment the maximum that it may be expected that the protection below the level of international minimum each state is free to treat its nationals is not the case in regard to foreign of a national treatment provision does imposed by the international law49).
The third observation concerns the degree of protection accorded persons
and property, and the specific reference to international law. What constilanguage,
without leaving their inclusion to be implied." See also Wilson, Pro*
perty-Protection Provisions in United States Commercial Treaties in American
Journal of International Law Vol. 45 (195 1) p. 83, 100.
46) Hackworth, Digest of International Law, Vol. III. 1942, at p. 431-433;
Vfalker, supra note 23, at p. 377-378. British practice would seem to be in accord
with this; see Mervyn Jones, Claims on Behalf of Nationals Who Are Shareholders
in Foreign Corporations in British Yearbook of International Law Vol. 26 (1949)
p. 225, 228. But see, Protocol modifying commercial treaty with Finland (1952),
4 United State Treaties 2047, 205 United Nations Treaty Series 149, in which the
term "nationals" is used with no reference to companies.
47) See Wilson, Property-Protection Provisions in United States Commercial
Treaties, supra note 45, at p. 85-86, and the authorities cited therein. See also,
Wilcox, op. cit. supra note 5, at p. 31-32, 145-148; Fenwick, The Ninth international
Conference of American States in American Journal of International Law
Vol 42 (1948) p. 533; id., The Revision of the Pact of Bogota in American Journal
of International Law Vol. 48 (1954) p. 123; id. The Tenth Inter- American Conference
at Caracas in American Journal of International Law Vol. 48 (1954) p. 136;
/. N. Hyde, Permanent Sovereignty Over Natural Wealth and Resources in American
Journal of International Law Vol. 50 (1956) p. 854; Lockwood, The Economic
Agreement of Bogota in American Journal of International Law Vol. 42 (1948)
p. 608.
48) See Wilson, supra note 47, at p. 86-87, and the authorities cited therein.
49) See Scbwarzenberger, op. cit. supra note 8, at p. 248: "Even if the standard
of national treatment is laid down in a treaty, the presumption is that it has been
the intention of the parties to secure to their nationals in his manner additional
advantages, but not to deprive them of such rights as. in any case, they would be
entitled to enjoy under international customary law or the general principles of
law recognized by civilized nations."
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment i6y
tutes "the most constant protection" would be for a judicial tribunal to
decide, but it is, at the very least, that protection required by the minimum
standards of international customary law50).
The fourth observation concerns the meaning of "property" as used in
the property protection provisions. Does it include all property? Would it
include the good will and tangible property of a partially owned American
subsidiary company incorporated under the laws of the contracting foreign
state? The latter would seem to be a reasonable question to a lawyer today
in view of the current mode of operating abroad through foreign incorporated
subsidiaries. However, a definite answer to this question cannot
be given. The word "property" would have to be interpreted in the light
of the intention of the parties at the time the agreement was reached, and
not in light of current practices51). Unfortunately, this indefiniteness, apparent
here as well as under our third observation, still exists in present-day
property protection provisions, and is the price that must be paid for broad
and very general protection.
Finally, the question arises as to what constitutes "due process" and
"payment of just compensation". The above phrases do not necessarily require
that which would be required under the United States Constitution52).
In the absence of specific provisions to that effect, no municipal law of a
state, either of the contracting parties or a third state, would govern. The
agreement, being one between two sovereign states, would be governed by
public international law, and "due process", "payment" and "just compensation"
would be that which is required by international law53).
Under international law would payment in a blocked account, or in the
currency of the foreign state constitute "payment"? Must the payment be
at the time the property is taken, or a reasonable time thereafter, or at any
time? Once again it is difficult to give definite answers. But this time the
defect is not in the treaty, but in international law itself. Opinions differ as
to what is required by international law, and the answers to these questions
remain highly controversial54).
Our examination of the standard property protection provisions of post-
World War I commercial treaties has raised a number of questions. We shall
now examine post- World War II property protection provisions to determine
to what extent the above questions are answered and added protection
is provided to foreign property owners.
50) Ibid.
51) See Hyde, op. cit. supra note 7, Vol. II, § 533 H at p. 1495; McNair, The
Law of Treaties, 1938, p. 252; Oppenheim, International Law, Vol. I. 8th edition
1955. § 554 at p. 953; Schwarzenberger, op. cit. supra note 8, at p. 490.
52) Wilson, supra note 42, at p. 101.
J3) Ibid.
54) See note 8 supra.
1 8*
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
268 H. P. Connell
V. Property Protection Provisions in Post-World
War II Commercial Treaties
For purposes of illustration, abstracts of treaty provisions are contained
on charts 2, 3, 4, 5, 6 and 7 M). It is essential to be mindful of the fact abstracted parts of provisions found on the charts are usually merely of one article, and that the particular article is just one of many which compose a treaty. It is imperative, when interpreting a interpret it as a whole, without putting undue stress on any particular in this case the property protection provisions. This applies equal force to the previous section in which we examined the property provisions in earlier treaties. Although the same provision in each treaty, in each case it would have to be interpreted as part treaty in which it appears, rather than in the abstract.
The provisions from post- World War II treaties of friendship, commerce
and navigation on charts 2, 3, 4 and 5 contain significant changes standard provisions examined in the preceeding section. All of the protection provisions in the post- World War II treaties provide that shall extend to corporations and associations56). Thus, protection longer restricted to nationals, and the question of protection for is resolved.
The words "the most constant protection and security" appear property protection provision, but a specific reference to "international appears only in the treaties with China (1946), Italy (1948), Ireland and Iran (1955). The reference to international law is not necessary in the absence of specific agreement to the contrary, the treaty governed by international law.
The provisions dealing with expropriation and compensation further in protecting property owners than did their counterparts post- World War I treaties. Whereas the earlier treaties provided of just compensation", present-day provisions provide significant protection. Beginning with the treaty with China (1946) which provided "the payment of just and effective compensation", the provisions developed to thé point where the most commonly found provision not only for the prompt payment of just compensation, but provides 55) Reprinted infra at pp. 306 et seq. Before referring to these diarts caution. They are presented to aid the reader in understanding the commentary the property-protection provisions of the post- World War II commercial and by presenting the provisions in chronological order, to reveal the development
and changes that have occurred. Frequently modifications and exceptions in articles at the end of a treaty, as we.ll as in "Protocols", "Additional and in the final "Exchange of Notes". Therefore, in no case should the used in definitive reference for the terms of a treaty.
56) See text at notes 23, 24 and 25 supra.
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment 269
that the property shall not be taken except for public purposes, that compensation
shall be in an effectively realizable form representing the (full)
equivalent of the property taken, and that adequate provision be made for
timely payment thereof57).
The basic standard in the provisions dealing with the protection of property
is the minimum standards of international law. This represents no
change from the post- World War I provisions. However, several provisions
include, in addition to the minimum standards, the standards of national
treatment and most-favored-nation treatment58). The addition of these
standards gives significant protection to the foreign property owner since
the standard of treatment is less indefinite under national treatment and
most-favored-nation treatment than it is under the minimum standards of
international law. This represents a valuable improvement over the post-
World War I provisions59).
The problem of the compatibility of treaty provisions with domestic law
was resolved in several treaties by what is called "screening"60). The enjoyment
of national treatment and most-favored-nation treatment is thereby
made dependent upon compliance with applicable laws and regulations.
Whether the applicable laws and regulations are discriminatory will depend
once again on the good faith of the contracting parties.
When examining the standard post- World War I property protection
provision a question arose concerning the meaning of the word "property".
In this regard it is significant that several of the treaties contain the following
provisions which, because of space limitations, could not be put on
the charts: "Moreover, enterprises in which nationals and companies of either
Party have a substantial interest shall be accorded, within the territories of
the other Party, not less than national treatment and most-favored-nation
treatment in all matters relating to the taking of privately owned enterprises
into public ownership and to the placing of such enterprises under public
control"61).
57) See diarts 2, 3, 4, 5, 6 and 7 appended (infra at pp. 306 et seq.).
58) Ibid.
59) In this respect, national treatment and most- favored-nation treatment standards
do not appear in the treaties with: Israel (195 1), 5 United States Treaties
550, 219 United Nations Treaty Series 237; Ethiopia (195 1), 4 United States Treaties
2134, 206 United Nations Treaty Series 41; Iran (1955), 8 United States Treaties
899, Treaties and Other International Acts Series No. 3853; Korea (1956), 8
United States Treaties 2217, Treaties and Other International Acts Series No. 3947.
60) See note 39 supra.
61) Treaties of friendship commerce and navigation with: Ireland (1950), 1 United
States Treaties 785, 206 United Nations Treaty Series 269, Art. VIII, par. 3;
Israel (195 1), 5 United States Treaties 550, 219 United Nations Treaty Series 237,
Art. VI, par. 5; Japan (1953), 4 United States Treaties 2063, 206 United Nations
Treaty Series 143, Art. VI, par. 4; Federal Republic of Germany (1954), 7 United
States Treaties 1839, Treaties and Other International Acts Series No. 3593, Art. V,
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
270 H. P. Connell
There remains to be examined the various provisions restrictions and their effect on repatriation of the repatriation of capital appear for the first treaty with China (1946). As distinguished (1946) and Italy (1948) which provided for "and most-favored-nation treatment, nearly all for unrestricted national treatment and most-The two exceptions are the treaties with Ethiopia All of the post- World War II treaties provide acknowledge their obligations as members of Fund«3).
What might be called the standard exchange that: (1) contracting states acknowledge Monetary Fund; (2) exchange restrictions when necessary to maintain monetary reserves; are imposed, each state shall, after making assure the health and welfare of its people, provide of capital.
The following is a further provision frequently provisions which was omitted from the aIf more than one rate of exchange is in force, withdrawals shall be a rate which is specifically 6; Netherlands (1956), 8 United Nations Treaties Treaty Series 231, Art. VI, par. 5; Korea (1956), Treaties and Other International Acts Series No. (1956), Treaties and Other International Acts Series Pakistan (1956), Art. VI, par. 5. See also treaties navigation with: Italy (1948), 63 Stat. (2) 2255, 171, Art. V, par. 3; Greece (1951), 5 United States Nations Treaty Series 279, Art. 7, par. 4. The latter par. 3 : "The provisions of the present paragraph directly or indirectly by nationals and companies of is taken within the territory of the other Party." protocols in the treaties with Nicaragua (1956), Protocol 3; and France (1959), Protocol 5. In regard indirect ownership of property, see Foighel, op. cit. 62) See charts 2, 3, 4, j, 6 and 7 appended (intra 63) It would appear from the wording of the treaty States Treaties 550, 219 United Nations Treaty (see chart 3 appended) that the contracting parties contract out of obligations they assumed on a multilateral International Monetary Fund. The United States away rights they have acquired as members of the barring provisions in the Article of the Agreement Fund to the contrary. However, they are not free obligations assumed in a multilateral agreement, unless so provides, or the parties to it give their consent.
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment 27 1
tional Monetary Fund for such transactions or, in the absence of a rate so
approved, an effective rate which, inclusive of any taxes or surcharges or
exchange transfers, is just and reasonable" 64).
By providing for national treatment and most-favored-nation treatment,
the repatriation of capital provisions prevent the use of exchange controls
as a means of discriminating against foreign investors, thus according needed
protection. However, although the exceptions permitting the use of exchange
restrictions are reasonable, the fact remains that international monetary
imbalances of payments may cause periodical exchange stringencies. The
manner in which they are handled and the consequent effect on foreign
investors will once again depend largely on the good faith of the contracting
parties concerned.
VI. The Evaluation of Treaty Protection
In the preceding part of this paper when examining the property protection
provisions it was necessary to keep in mind that each provision had to
be interpreted as part of the particular treaty in which it appeared, without
undue stress on the particular provision being examined. Likewise, when
evaluating treaties of friendship, commerce and navigation in general, it is
necessary to be mindful of their place in international relations and of the
limitations of the international judicial system which governs them. To
examine them in the abstract, rather than in the international milieu in which
they belong, would produce merely legal conclusions of limited practical
value.
To evaluate treaties of friendship, commerce and navigation it is necessary
to understand what they are, as well as the judicial system under which
they function. In terms of municipal law, they are bilateral contracts85),
and have as their quid pro quo mutuality of benefit. By the terms of the
agreements each party agrees to accord rights to nationals and companies of
the other party. The contract is one which requires continuous performance,
in contrast to a contract which has as its quid pro quo an act limited in
time, which when completed, renders the contract performed.
64) Treaties with: Israel (195 1), 5 United States Treaties 550, 219 United Nations
Treaty Series 237, Art. XII, par. 4; Japan (1953), 4 United States Treaties
2063, 206 United Nations Treaty Series 143, Art. XII, par. 3; Iran (1955), 8 United
States Treaties 899, Treaties and Other International Acts Series No. 3853,
Art. VII, par. 2; Netherlands (1956), 8 United States Treaties 2043, 285 United
Nations Treaty Series 231, Art. XII, par. 3; Korea (1956), 8 United States Treaties
2217, Treaties and Other International Acts Series No. 3947, Art. XII, par. 3.
65) See Brierly, Some Considerations on the Obsolescence of Treaties in Transactions
of the Grotius Society for 1925, at p. 11; Brierly, The Basis of Obligations
in International Law, 1958, p. 108.
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
lyi H. P. Connell
Treaties of friendship, commerce and navigation international law, and their violation is unlawful All these post- World War II treaties provide them shall be submitted to the International the power of enforcement inherent in the manifest. Should it be necessary to have recourse system to enforce an agreement, the system case a legal evaluation of the terms of the treaty function properly, in which case a strictly significance. To evaluate treaties of friendship, solely on their terms would involve the assumption judicial system will function properly, and possibility that it may not function properly.
In the absence of a reliable law enforcing of an agreement rests with the contracting to a consideration of the conditions under comply with the terms of an agreement. There be taken into consideration in answering this Of primary importance is the treaty itself, the agreement will be honored and that the In our examination of post-World War II FCN have undergone a shift in emphasis, and in problems provide much needed protection added protection deserves emphasis. However, provisions are more comprehensive than they have, nevertheless, significant taken into consideration.
Since the provisions attempt to provide for are very general in nature, and consequently interpretations. What is "necessary", could be very debatable even when both parties Likewise, that certain standards of protection with local laws does not guarantee again emphasizes the importance of good faith.
Should a contracting state not honor the terms Government of the United States which will United States national will have no cause of the claim by the Government will be dependent the international political circumstances 66) See Friedmann, op. cit. supra note 16, at p. are less general and more definite since each one too have limitations. Id. at p. 733.
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment 273
thereof, not to mention the uncertainties and difficulties of international
litigation after espousal by the Government67).
Apart from the treaty itself, another important factor is mutuality of benefit,
which is the basis of treaties of friendship, commerce and navigation.
The problem of maintaining mutuality of benefit, or, in other words, adjusting
quid pro quo as circumstances change with the passage of time, is not
a new one. In labor-management contracts various types of escalator clauses
and re-negotiation provisions have been used to solve the problem. In an
area closer to international law, most of the more recent concession agreements
have incorporated within them re-negotiation provisions which provide
that the terms of the agreements can be examined and adjusted bilaterally,
thus creating a living contract, capable of adjustment, rather than
a static one which may become anachronistic with the passage of time.
Admittedly, there is less need for adjustment in treaties of friendship,
commerce and navigation than in private contracts. In the latter, the profits
of the contractants may be influenced in a short period of time by many
factors. Whereas, these treaties, by their very nature, tend to become obsolete
at a much slower rate, barring revolutions and large scale international
disturbances. Many of the provisions merely treatify rules which the parties
believe to be international customary law, and in this regard, the object is
to solidify the terms of the agreement rather than make them flexible68).
However, there are many provisions in treaties of friendship, commerce
and navigation which are not declaratory of existing principles of international
law which bind the states inter se as long as the treaties exist. It is
67) Ibid. For conditions precedent to espousal by the Government, see Clay,
supra note 9, at p. 7.
68) In this regard, compare: Brandon, supra note 5, at p. 307: "Since essentially
these treaties each contain the same general provisions, it is submitted they may be
regarded as a method whereby conventional international law is evidenced by a
quasi-multilateral treaty system composed of a series of bilateral treaties containing
substantially similar terms and a party common to each. They are, it is further
submitted, themselves generally illustrative of current prevailing rules of international
law" with, Friedmann, op. cit. supra note 16, at p. 733: aThe particular
provisions of the various instruments present, as we have seen, strong similarities
to each other. They may be seen as heralding the development of a body of common
international law. Its precise contents would be found in the provisions of
treaties and investment laws, as well as contracts and 'instruments of approval* . . .
Of course, it would be fallacious to maintain that such a body of law exists today.
It is only now beginning to be formed and its future existence is still uncertain"
and, Foighel, op. cit. supra note 8, at p. 85: "It must be admitted, nevertheless,
that it is not possible solely on the basis of international treaty practice to give a
definite answer to the question whether lawful nationalization entails a liability
to pay compensation to the victim of the same in case they are nationals of a
foreign state. Treaty practice up till now has not been extensive enough, and in
some respects has been too special in character, to be a basis for a decisive attitude
to this question."
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
274 #• P» Connell
these static provisions which, when viewed from century international political and economic change, from the point of view of one of the contracting Another consideration under the factor of mutuality of investment contemplated. Does it require large a number of years before it will become profitable, a small capital outlay with prospects what degree can the proposed enterprise be geared requirements of the country in which it is which is primarily concerned with the extraction may, because of its very nature encounter resistance the psychological distrust of foreign capital and of exploitation and profiteering. Whereas, a secondary consumer goods may not encounter such a problem.
The fact is that the day of exploitation is corporations have learned that they have obligations which they are located, as well as to the country foreign investor must accept his responsibilities there is social and economic integration of an there will be less likelihood of having for protection.
The date of the agreement relied upon is a significant recent date it probably reflects a favorable investment the agreement the country indicates that acknowledges its need for, foreign investment, to get it71).
As mentioned above, good faith is a significant of time and change of circumstances effect good faith of the parties may create the necessary to their agreement. When states honor treaty "good faith" is frequently cited by the contracting of the particular state's practice with regard well as its treatment of property in general under for expropriation, may prove significant.
Another factor to consider is the particular civilization 69) All of the post- World War II commercial that they shall remain in force for ten years, and terminated by either party by one year's written notice.
70) Clay, supra note 65, at p. 18; Ltttell, Legal Abroad in Virginia Law Review Vol. 40 (1954) 71) Fnedmann, op. cit. supra note 16, at p. 709.
72) See Scbwarzenberger, The Fundamental Principles Law; Recueil des Cours Vol.87 (I95Í> I) at P- 29°- Principles of Law as applied by International Courts This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment 27 5
tracting state belongs. Is it part of our western civilization, reflecting in its
culture the deep rooted respect for private property which is basic to western
legal systems and reflected in international customary law? Or, is it a
country which has consistently stated that it recognizes no restriction of its
sovereignty with regard to property rights, that national treatment is all
chat any foreigner can claim, and that there is no rule of international customary
law to the contrary73)?
Other factors include the stability of the government of the contracting
state. Is it securely rooted, or threatened by revolution and apt to topple at
any time? It is a soft-currency underdeveloped country which may honor
its international agreements in order to encourage foreign investment, and
also to keep open the possibilities of investment through foreign and international
institutions such as the United States Export-Import Bank or the
World Bank74)? What is its geographical location is its international political
alignment?
Admittedly, under a perfected international judicial system many of die
above considerations would be irrelevant. However, under present circumstances,
to evaluate an international agreement as a legal document without
considering power politics and the East- West split would be to fall prey to
the prevalent fallacy of "legalism" 75).
That Iran and Egypt were legally bound by international agreements was
certainly of less significance than the fact that geographically they are located
between the two opposing world forces, and thus, were able to
violate international law with impunity. Unfortunately, the problem cannot
be reduced into a purely legal one because it is inextricably tied to the
everyday realities of economics and politics, and to solve it in a purely
legal sense would be to solve it in a vacuum.
VII. Conclusions
The factors which must be considered by a prospective foreign are so numerous that it is impossible to control or even influence a number of them to create artificially a favorable investment climate. most, only a few of the factors considered by prospective investors engaging in foreign investment can be made favorable towards investment.
Thus, with respect to the question of profitability, a tax incentive help to make the contemplated investment appear feasible from standpoint76). But, tax questions, although ubiquitous in this day 73) See note 47 supra.
74) See Friedmann, op. cit. supra note 16, at p. 782.
75) See Miller, supra note 18, at p. 377.
76) However, see Barlow and Wender, op. cit. supra note 5 at p. found no evidence to suggest that United States taxes has been an impediment had prevented particular investments in foreign countries. More important, This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
276 H.P.Connell
are merely one aspect of the problem of profitability. factors such as cost of transportation, nearness size of market, etc. which are of varying importance, is no control or, at most, limited control favorable investment climate77).
Likewise, the risk factor, although very important, of the many factors which must be considered. of friendship, commercé and navigation program consideration favorable to investment. Government Whereas, a negative answer to the consideration automatic veto on investment, a positive answer that investment will be made. It will be made the other considerations indicate that investment Within this framework, the question arises: treaties of friendship, commerce and navigation foreign investor? A definitive answer to this without entering the area of conjecture. Depending protection provided by such a treaty may be nil. It will depend on the interplay of many treaty of friendship, commerce and navigation Although this lacks the definiteness so often to be more definite would possibly be to mislead.
Each treaty must be evaluated separately on herein, as well as on others which may case. The factor of primary importance is reflect the amount of protection the investor law. If the contracting parties adhere law, the protection provided in the treaty will as time goes on the United Nations will grow authority, and that the force of world opinion found no instance where executives believed that from United States taxes would have tipped that had been made against a particular investment" 77) See id., at p. 217: "It is difficult to suggest that relate directly to the factors limiting investment primarily within the control of foreign countries." p. 84-85: "It is often suggested that the negotiation the investment climate abroad, augment investment capital. There is unfortunately little merely an assumption. . . . ability to negotiate treaty generally reflects an already-existent climate The treaty tends to record the fact, not create it."
78) See notes 2 and 3 supra.
79) See Friedmann, op. cit. supra note 16, at p. This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
United States Protection of Investment zyy
states will strengthen the international rule of law. However, in the meantime,
one must think realistically.
With this in mind, it is submitted that besides the treaty itself, the circumstances
under which it will be honored must be considered. The motives,
such as ethics, fear, power, benefit, etc., which underlie the observance by
states of international treaty obligations are generally mixed and vary in
primacy with time. However, it is the manifestations of these motives in
the everyday realities of the international existence of states which must be
considered before a realistic evaluation of treaty protection can be made.
In this regard, some of the more important factors to be considered
include: the date of signature of the treaty (Does it reflect a favorable investment
climate?); lapse of time and the nexus of change of circumstances
and mutuality of benefit; international economic and political stability;
international and national state practice; alignment in international politics;
and the current state of international tensions. Any evaluation of the protection
accorded by an treaty of friendship, commerce and navigation which
did not take into consideration the international milieu to which the treaty
is indigenous as an international agreement would be too unrealistic to be
seriously considered.
In concluding, it would be difficult to improve upon the last three sentences
of a recent book on the subject of foreign investment80): "But until international
society has reached a degree of integration, which will provide
for additional powers inherent in the international community as such, it
behooves the lawyer to be aware of the limit of equal protection for the
foreign investor. Legal arrangements will provide some ancillary protection.
The foreign investor's main safety, however, must reside in the correctness
of his estimates as to the economic and social stability of the country of
investment, and in the establishment of a moral as well as an economic
position in the foreign country, which will make drastic interference with
his interests unlikely."
80) Friedmann, op. cit. supra note 16, at p. 783.
This content downloaded from 169.252.4.22 on Thu, 01 Aug 2019 14:45:40 UTC
All use subject to https://about.jstor.org/terms
Annex 157
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 158
Annex 159
Annex 159
Annex 159
Annex 159
Annex 159
Annex 160
Annex 160
Annex 160
Annex 160
Annex 160
Annex 160
Annex 160
Annex 160
Annex 160
Annex 161
Annex 161
Annex 161
Presidential Documents
Federal Register / Vol. 62, No. 162 / Thursday, August 21, 1997 / Presidential Documents 44531
Executive Order 13059 of August 19, 1997
Prohibiting Certain Transactions With Respect to Iran
By the authority vested in me as President by the Constitution and the
laws of the United States of America, including the International Emergency
Economic Powers Act (50 U.S.C. 1701 et seq.) (‘‘IEEPA’’), the National Emergencies
Act (50 U.S.C. 1601 et seq.), section 505 of the International Security
and Development Cooperation Act of 1985 (22 U.S.C. 2349aa-9) (‘‘ISDCA’’),
and section 301 of title 3, United States Code,
I, WILLIAM J. CLINTON, President of the United States of America, in
order to clarify the steps taken in Executive Orders 12957 of March 15,
1995, and 12959 of May 6, 1995, to deal with the unusual and extraordinary
threat to the national security, foreign policy, and economy of the United
States declared in Executive Order 12957 in response to the actions and
policies of the Government of Iran, hereby order:
Section 1. Except to the extent provided in section 3 of this order or
in regulations, orders, directives, or licenses issued pursuant to this order,
and notwithstanding any contract entered into or any license or permit
granted prior to the effective date of this order, the importation into the
United States of any goods or services of Iranian origin or owned or controlled
by the Government of Iran, other than information or informational materials
within the meaning of section 203(b)(3) of IEEPA (50 U.S.C. 1702(b)(3)),
is hereby prohibited.
Sec. 2. Except to the extent provided in section 3 of this order, in section
203(b) of IEEPA (50 U.S.C. 1702(b)), or in regulations, orders, directives,
or licenses issued pursuant to this order, and notwithstanding any contract
entered into or any license or permit granted prior to the effective date
of this order, the following are prohibited:
(a) the exportation, reexportation, sale, or supply, directly or indirectly,
from the United States, or by a United States person, wherever located,
of any goods, technology, or services to Iran or the Government of Iran,
including the exportation, reexportation, sale, or supply of any goods, technology,
or services to a person in a third country undertaken with knowledge
or reason to know that:
(i) such goods, technology, or services are intended specifically for supply,
transshipment, or reexportation, directly or indirectly, to Iran or the Government
of Iran; or
(ii) such goods, technology, or services are intended specifically for use
in the production of, for commingling with, or for incorporation into goods,
technology, or services to be directly or indirectly supplied, transshipped,
or reexported exclusively or predominantly to Iran or the Government of
Iran;
(b) the reexportation from a third country, directly or indirectly, by a
person other than a United States person of any goods, technology, or
services that have been exported from the United States, if:
(i) undertaken with knowledge or reason to know that the reexportation
is intended specifically for Iran or the Government of Iran, and
(ii) the exportation of such goods, technology, or services to Iran from
the United States was subject to export license application requirements
under any United States regulations in effect on May 6, 1995, or thereafter
Annex 162
44532 Federal Register / Vol. 62, No. 162 / Thursday, August 21, 1997 / Presidential Documents
is made subject to such requirements imposed independently of the actions
taken pursuant to the national emergency declared in Executive Order 12957;
provided, however, that this prohibition shall not apply to those goods
or that technology subject to export license application requirements if such
goods or technology have been:
(A) substantially transformed into a foreign-made product outside the United
States; or
(B) incorporated into a foreign-made product outside the United States
if the aggregate value of such controlled United States goods and technology
constitutes less than 10 percent of the total value of the foreign-made product
to be exported from a third country;
(c) any new investment by a United States person in Iran or in property,
including entities, owned or controlled by the Government of Iran;
(d) any transaction or dealing by a United States person, wherever located,
including purchasing, selling, transporting, swapping, brokering, approving,
financing, facilitating, or guaranteeing, in or related to:
(i) goods or services of Iranian origin or owned or controlled by the
Government of Iran; or
(ii) goods, technology, or services for exportation, reexportation, sale, or
supply, directly or indirectly, to Iran or the Government of Iran;
(e) any approval, financing, facilitation, or guarantee by a United States
person, wherever located, of a transaction by a foreign person where the
transaction by that foreign person would be prohibited by this order if
performed by a United States person or within the United States; and
(f) any transaction by a United States person or within the United States
that evades or avoids, or has the purpose of evading or avoiding, or attempts
to violate, any of the prohibitions set forth in this order.
Sec. 3. Specific licenses issued pursuant to Executive Orders 12613 (of
October 29, 1987), 12957, or 12959 continue in effect in accordance with
their terms except to the extent revoked, amended, or modified by the
Secretary of the Treasury. General licenses, regulations, orders, and directives
issued pursuant to those orders continue in effect in accordance with their
terms except to the extent inconsistent with this order or to the extent
revoked, amended, or modified by the Secretary of the Treasury.
Sec. 4. For the purposes of this order:
(a) the term ‘‘person’’ means an individual or entity;
(b) the term ‘‘entity’’ means a partnership, association, trust, joint venture,
corporation, or other organization;
(c) the term ‘‘United States person’’ means any United States citizen,
permanent resident alien, entity organized under the laws of the United
States (including foreign branches), or any person in the United States;
(d) the term ‘‘Iran’’ means the territory of Iran and any other territory
or marine area, including the exclusive economic zone and continental
shelf, over which the Government of Iran claims sovereignty, sovereign
rights, or jurisdiction, provided that the Government of Iran exercises partial
or total de facto control over the area or derives a benefit from economic
activity in the area pursuant to international arrangements;
(e) the term ‘‘Government of Iran’’ includes the Government of Iran, any
political subdivision, agency, or instrumentality thereof, and any person
owned or controlled by, or acting for or on behalf of, the Government
of Iran;
(f) the term ‘‘new investment’’ means:
(i) a commitment or contribution of funds or other assets; or
(ii) a loan or other extension of credit, made after the effective date
of Executive Order 12957 as to transactions prohibited by that order, or
otherwise made after the effective date of Executive Order 12959.
Annex 162
Federal Register / Vol. 62, No. 162 / Thursday, August 21, 1997 / Presidential Documents 44533
Sec. 5. The Secretary of the Treasury, in consultation with the Secretary
of State and, as appropriate, other agencies, is hereby authorized to take
such actions, including the promulgation of rules and regulations, the requirement
of reports, including reports by United States persons on oil and
related transactions engaged in by their foreign affiliates with Iran or the
Government of Iran, and to employ all powers granted to me by IEEPA
and the ISDCA as may be necessary to carry out the purposes of this
order. The Secretary of the Treasury may redelegate any of these functions
to other officers and agencies of the United States Government. All agencies
of the United States Government are hereby directed to take all appropriate
measures within their authority to carry out the provisions of this order.
Sec. 6. (a) The Secretary of the Treasury may authorize the exportation
or reexportation to Iran or the Government of Iran of any goods, technology,
or services also subject to export license application requirements of another
agency of the United States Government only if authorization by that agency
of the exportation or reexportation to Iran would be permitted by law.
(b) Nothing contained in this order shall be construed to supersede the
requirements established under any other provision of law or to relieve
a person from any requirement to obtain a license or other authorization
from another department or agency of the United States Government in
compliance with applicable laws and regulations subject to the jurisdiction
of that department or agency.
Sec. 7. The provisions of this order consolidate the provisions of Executive
Orders 12613, 12957, and 12959. Executive Order 12613 and subsections
(a), (b), (c), (d), and (f) of section 1 of Executive Order 12959 are hereby
revoked with respect to transactions occurring after the effective date of
this order. The revocation of those provisions shall not alter their applicability
to any transaction or violation occurring before the effective date of
this order, nor shall it affect the applicability of any rule, regulation, order,
license, or other form of administrative action previously taken pursuant
to Executive Orders 12613 or 12959.
Sec. 8. Nothing contained in this order shall create any right or benefit,
substantive or procedural, enforceable by any party against the United States,
its agencies or instrumentalities, its officers or employees, or any other
person.
Sec. 9. The measures taken pursuant to this order are in response to actions
of the Government of Iran occurring after the conclusion of the 1981 Algiers
Accords, and are intended solely as a response to those later actions.
Sec. 10. (a) This order is effective at 12:01 a.m. eastern daylight time on
August 20, 1997.
(b) This order shall be transmitted to the Congress and published in
the Federal Register.
oe–
THE WHITE HOUSE,
August 19, 1997.
[FR Doc. 97–22482
Filed 8–20–97; 11:16 am]
Billing code 3195–01–P
Annex 162
8/12/2019 Iran killed more US troops in Iraq than previously known, Pentagon says
https://www.militarytimes.com/news/your-military/2019/04/04/iran-killed… 1/5
Your Military (//www.militarytimes.com/news/your-military/)
Iran killed more US troops in Iraq than previously known, Pentagon says
By: Kyle Rempfer (/author/Kyle Rempfer) April 4
166
Correction: A previous version of this article reported that the number of U.S. troops in Iraq killed by Iranian-backed militants was at least 608, as written in a State
Department transcript. However, the correct number is 603, according to a follow-up statement by the Pentagon.
The Pentagon is upping the official estimate on the number of U.S. troops in Iraq who were killed by Iranian-backed militias, now putting that number at at least 603.
Officials previously said that Iran was linked to the deaths of roughly 500 troops (https://www.militarytimes.com/news/pentagon-congress/2015/07/14/iran-li…-
of-500-u-s-troops-in-iraq-afghanistan/).
That means roughly one in every six American combat fatalities in Iraq were attributable to Iran.
The deaths are attributed to proxies sponsored by the Islamic Revolutionary Guard Corps — Iran’s elite military force that protects the regime from internal and external
threats.
“During Operation Iraqi Freedom, DoD assessed that at least 603 U.S. personnel deaths in Iraq were the result of Iran-backed militants,” Navy Cmdr. Sean Robertson, a
Pentagon spokesman, said in an email.
“These casualties were the result of explosively formed penetrators (EFP), other improvised explosive devices (IED), improvised rocket-assisted munitions (IRAM),
rockets, mortars, rocket-propelled grenades (RPG), small-arms, sniper, and other attacks in Iraq," Robertson said.
The Pentagon did not provide Military Times with the new report to independently assess.
The new assessment was given to the State Department and reported to the press during a briefing Tuesday.
“This death toll is in addition to the many thousands of Iraqis killed by the IRGC’s proxies," State Department deputy spokesman Robert Palladino said during the press
brief.
Sign up for the Early Bird Brief
Get the military's most comprehensive news and information every morning
Subscribe
Annex 163
8/12/2019 Iran killed more US troops in Iraq than previously known, Pentagon says
https://www.militarytimes.com/news/your-military/2019/04/04/iran-killed… 2/5
That new total accounts for 17 percent of all deaths of U.S. personnel in Iraq (https://www.militarytimes.com/news/your-military/2018/08/20/us-to-remai…-
as-needed-command-says/) from 2003 to 2011, the State Department said.
“That’s a Department of Defense statistic," Palladino added.
Most of the deaths occurred during the surge in Iraq, when President George W. Bush pushed thousands more troops into the country to deal with the sectarian civil war
boiling over between Shiite and Sunni groups.
American personnel in Iraq faced off against highly lethal bombs, like the EFPs, which were allegedly manufactured and supplied by Iran to Shiite militias across the
border in Iraq.
Lawsuits filed in U.S. District Court (https://www.militarytimes.com/news/your-military/2015/04/01/lawsuit-all…) in
Washington have previously attempted to hold the Iranian government legally accountable for the deaths of Americans that died from these weapon systems.
(https://www.militarytimes.com/news/your-military/2018/12/02/victims-loo…)
Victims look to punish Iran for attacks against US troops in Iraq (https://www.militarytimes.com/news/yourmilitary/
2018/12/02/victims-look-to-punish-iran-for-attacks-against-us-troops-in-iraq/)
The lawsuit is asking for $10 billion in damages for the victims and their families.
By: Todd South
166
Recommended for you
Afghanistan president rejects foreign interference as US-Taliban talks
advance
(http://www.militarytimes.com/news/pentagoncongress/
2019/08/11/afghanistan-president-rejects-foreign-interference-as-ustaliban-
talks-advance/?utm_source=clavis)
Military children have more health care needs, but less access and
lower quality, study finds
(http://www.militarytimes.com/pay-benefits/2019/08/05/military-childrenh…-
more-health-care-needs-but-less-access-and-lower-quality-study-finds/?
utm_source=clavis)
Pentagon identifies Marine Raider killed in Iraq
(http://www.militarytimes.com/news/your-army/2019/08/12/pentagon-idsmari…-
killed-in-iraq/?utm_source=clavis)
Russia’s military drone makes successful maiden flight
(http://www.militarytimes.com/news/pentagon-congress/2019/08/07/russiasm…-
drone-makes-successful-maiden-flight/?utm_source=clavis)
Around The Web
Recommended by
Annex 163
Volume IV - Annexes 134-163