Iranian Oil Sector Designations
The Office of Foreign Assets Control of the US Department of the Treasury has designated the Iranian Ministry of Petroleum, the National Iranian Oil Company (NIOC), and the National Iranian Tanker Company (NITC) pursuant to Executive Order 13224 for their support of the Islamic Revolutionary Guard Corps-Qods Force, a designated entity. NIOC is responsible for the transportation of crude oil exports from Iran, and its subsidiary, NITC, supplies tankers to transport the oil.
According to OFAC, NIOC and NITC have coordinated with the Central Bank of Iran to collect millions of dollars in oil revenue for the benefit of the IRGC-QF, have helped generate revenue for Hizballah, and have disguised their activities by setting up front companies in the United Arab Emirates.
In addition to these major players in the Iranian oil industry, OFAC has designated seven subsidiaries of the Ministry of Petroleum, also pursuant to Executive Order 13224, for acting on behalf of the Ministry. Furthermore, six officials of the designated entities have themselves been designated, including the Minister of Petroleum and the managing directors of NITC, NIOC, and a NIOC subsidiary in Switzerland, for their leadership roles within a designated entity or work in support of a designated person. Two NIOC-controlled vessels have also been designated.
OFAC has also designated Mobin International Limited, a UAE-based company, pursuant to Executive Order 13224 for entering into an agreement with a designated Venezuelan state-owned oil company and for its support of a NIOC subsidiary in the charter of vessels to transport tens of thousands of tons of gasoline to Venezuela. Mahmoud Madanipour, Mobin’s owner, and two UK-based companies owned by Madanipour, have also been designated.
Following these sanctions, US property of the sanctioned persons and entities is blocked, and US persons are generally prohibited from engaging in transactions with them. Likewise, foreign financial institutions that knowingly facilitate transactions for designated persons risk exposure to sanctions.
In an effort to clarify the position of US persons vis-à-vis NIOC, NIOC-controlled entities, and the Central Bank of Iran, which was designated in September 2019 pursuant to Executive Order 13224, OFAC has issued an amended General License 8A pursuant to the Iranian Transactions and Sanctions Regulations and the Global Terrorism Sanctions Regulations.
General License 8A, “Authorizing Certain Humanitarian Trade Transactions Involving the Central Bank of Iran or the National Iranian Oil Company,” replaces General License 8. It allows some transactions that would otherwise be prohibited by the ITSR and GTSR, but does not authorize the exportation of goods listed in ITSR 560.530(a)(1)(ii) to the CBI or NIOC or NIOC-controlled entities, or transactions that are otherwise prohibited by Executive Orders 13224 and 13886, the ITSR or the GTSR.
Frequently Asked Questions
FAQ 821 explains what General License 8A authorizes in terms of humanitarian activities involving the Central Bank of Iran or NIOC. FAQ 822 clarifies that transactions authorized under 560.530, 560.532, and 560.533 of the ITSR prior to the designation of NIOC and the Central Bank of Iran are still authorized. FAQ 823 confirms that non-US persons engaging in the sale of humanitarian goods to Iran generally do not risk exposure under US secondary sanctions. FAQ 825 addresses participation in the Swiss Humanitarian Trade Arrangement by persons domiciled in Switzerland. FAQ 828 describes the exemptions that apply to goods intended to help respond to the coronavirus pandemic, and FAQ 844 explains that non-US persons would not be subject to secondary sanctions pursuant to Executive Order 13902 for engaging in humanitarian activities authorized to US persons under the ITSR or general licenses.