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The new Iran sanctions regulations provide OFAC authority to prohibit or restrict correspondent and payable-through accounts of foreign financial institutions that knowingly conduct or facilitate significant transactions with persons designated under the new authorities outlined above. bank notes or precious metals by the Iran government (2) providing support, or goods or services in support of the National Iranian Oil Company (NIOC), the Nafitran Intertrade Oil Company (NIOC), or the Central Bank of Iran or (3) being part of the Iranian energy sector, shipping, or shipbuilding sectors, being a port operator in Iran, or providing significant support of persons designated as SDNs.
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The new Iran sanctions regulations provide new authority to designate SDNs to include any person that on or after Novemprovides material support or goods or services in support of persons designated for: (1) providing support, or goods or services in support of the purchase or acquisition of U.S. The new executive order also broadens the scope of sanctions in effect prior to the JCPOA dated January 16, 2016. The SREs, which must be renewed every six months, with the primary effect that these countries may continue to temporarily import Iranian-origin oil so long as certain conditions regarding the purchases are met. OFAC also announced significant reduction exceptions (“SREs”) to eight countries (China, India, Italy, Greece, Japan, South Korea, Taiwan, and Turkey) to allow those countries to temporarily continue to purchase Iranian oil. In addition, all activities under General License H will no longer be authorized. The final phase of Iran sanctions targets Iran’s port operators and shipping and ship-building sectors petroleum-related transactions financial transactions and specialized messaging services with the Central Bank of Iran underwriting and insurance services and Iran’s energy sector. sanctions, OFAC added more than 700 individuals, entities, aircraft, and vessels to the SDN List, including individuals and entities that had been removed from the SDN List in connection with the JCPOA as well as over 300 new targets. The 180-day wind-down period for termination of the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”) ended. On Novemthe Department of Treasury’s Office of Foreign Asset Control (“OFAC”) completed the process to re-impose the Iran sanctions program.