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Alerts and Updates

OFAC Issues Two General Licenses Affecting Iranian Transactions and Sanctions Regulations

September 10, 2013

OFAC Issues Two General Licenses Affecting Iranian Transactions and Sanctions Regulations

September 10, 2013

Read below

Unless otherwise prohibited, nongovernmental organizations are authorized to export or re-export services to or related to Iran in support of certain not-for-profit activities that are designed to directly benefit the Iranian people.

On September 10, 2013, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued two General Licenses affecting the Iranian transactions and sanctions regulations. General License E authorizes certain services in support of nongovernmental organizations' (NGOs) activities in Iran. Unless otherwise prohibited, nongovernmental organizations are authorized to export or re-export services to or related to Iran in support of certain not-for-profit activities that are designed to directly benefit the Iranian people. The activities include those related to humanitarian projects to meet basic human needs in Iran, including the provision of donated health-related services; operation of orphanages; relief services related to natural disasters; distribution of donated articles, such as food, clothing and medicine that are intended to relieve human suffering; and donated training related to the above.

In addition, General License E authorizes activities related to non-commercial reconstruction projects in response to natural disasters for a period of up to two years following the natural disaster; activities related to environmental and wildlife conservation projects in Iran involving endangered species; activities related to human rights and democracy building, which are more particularly set forth in General License E; and transfers of funds in support of activities as set forth in section (a) of General License E by a single NGO not exceeding USD $500,000 in the aggregate over a 12-month period.

General License E requires NGOs to submit quarterly reports, which include detailed descriptions of the services provided, along with any Iranian NGOs, Government of Iran entities, Iranian financial institutions or other Iranian persons involved in the activities. For specific details regarding coverage and exclusions, please refer to General License E on OFAC's website.

General License F authorizes certain services in support of professional and amateur sports activities and exchanges involving the United States and Iran.

U.S. depository institutions or U.S. registered brokers or dealers in securities are authorized to process transfers of funds in furtherance of activities authorized by General License F as long as the transfer is consistent with other regulations contained in 31 C.F.R. Part 560.

General License F "does not authorize any transaction by a U.S.-owned or -controlled foreign entity otherwise prohibited by 31 C.F.R. § 560.215 if the transaction would be prohibited by any other part of chapter V if engaged in by a U.S. person or in the United States."

For Further Information

If you would like further information about this Alert, please contact Brian S. Goldstein, any member of the International Practice Group or the attorney in the firm with whom you are regularly in contact.

As required by United States Treasury Regulations, the reader should be aware that this communication is not intended by the sender to be used, and it cannot be used, for the purpose of avoiding penalties under United States federal tax laws.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.