On June 5, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published four Frequently Asked Questions (FAQs) regarding Iran-related sanctions under Executive Order 13902 (EO 13902).  EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in “significant transactions” or providing “material support” to parties designated pursuant to the order.  Our blog post regarding EO 13902 is available here

The FAQs reconfirm that Iranian manufacturers of medicines, medical devices, or products used solely in Iran for sanitation, hygiene, medical care, medical safety, and manufacturing safety (including soap, hand sanitizer, ventilators, respirators, personal hygiene products, diapers, infant and childcare items, personal protective equipment, and manufacturing safety systems) will not be targeted under EO 13902 as operating in the manufacturing sector of the Iranian economy.  Further, persons facilitating transactions for the provision of agricultural commodities, medicine, or medical devices to Iran will not be subject to sanctions under EO 13902.

In addition, the FAQs provide definitions of the targeted sectors and the specific goods or services “used in connection with” the targeted sectors and provide OFAC’s interpretation of the key terms “knowingly” and “significant” for EO 13902 purposes. To read the rest of this article by Sylwia A. Lis, Lise S. Test and Ryan Poitras, please see our Sanctions Blog here.

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