ALERT: Clarifications of the Iranian Sanctions Regulations Published by the Office of Foreign Assets Control (OFAC)

On February 6, 2013, the Office of Foreign Assets Control (OFAC) published two guidance documents related to the Iranian sanctions regulations and licenses.  The first is Guidance on Humanitarian Assistance and Related Exports to the Iranian People.  While the guidance is simply an overview of previously-issued exceptions, the publication is nonetheless an indication of Washington’s efforts to encourage those projects and transactions that benefit the Iranian people directly.

In addition, OFAC published a Frequently Asked Questions document relating to the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”).  Specifically, the FAQ relates to modifications to the National Defense Authorization Act of 2012 included in ITRA § 504, effective as of February 6, 2013.  As with §§ 1244 and 1247 of the IFCPA (discussed above), § 504 provides that foreign financial institutions may face restrictions on their access to the U.S. financial system if they engage in financial transactions with the Central Bank of Iran or other designated Iranian financial institutions.