OFAC FAQs List Provides Details on June 3 Executive Order
The Treasury Department will be issuing regulations in the future to implement certain provisions of the June 3 executive order on implementing the Iran Freedom and Counter-Proliferation Act, the department's Office of Foreign Assets Control said in a new set of FAQs. It said Department of State also expects to adopt an interpretation of the E.O. similar to OFAC's.
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In general, OFAC said it intends to rely, where applicable, on definitions of terms previously included in Treasury regulations. It included general definitions of "Iran," "Iranian person," "knowingly," and other key terms.
The FAQ's note that there's "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." But it said the IFCA generally excepts from sanctions transactions involving "humanitarian" goods, such as the sale of agricultural commodities, food, medicine, or medical devices to Iran.