On June 5, 2020, the Department of the Treasury’s Office of Foreign Assets Control issued new Frequently Asked Questions 830 – 833, in order to clarify the provisions in Executive Order 13902 entitled, Imposing Sanctions With Respect to Additional Sectors of Iran. According to E.O. 13902, persons who knowing engage in significant transactions of goods and services in the construction, mining, manufacturing and textiles sectors of Iran’s economy risk exposure to blocking sanctions.
FAQ 830 confirms that OFAC will not target Iranian manufacturers of medications and medical devices or products used as personal protective equipment as long as the product is created solely for the use of persons within Iran, with no plan to export the product outside of Iran. FAQ 831 addresses how OFAC defines the construction, mining, manufacturing and textiles sectors of Iran’s economy that are subject to sanctions under E.O. 13902, and reiterates that the term “manufacturing” refers to the creation of goods that are for export from Iran or sale within Iran and does not include medications, medical devices and other health related items that are not intended to leave the country. FAQs 832 and 833 focus on what constitutes “significant goods and services” under the Order, with FAQ 833 providing guidance on how OFAC will interpret the terms “knowingly” and “significant” for purposes of E.O. 13902.