OFAC issued two FAQs on newly announced U.S. sanctions against Iran. The new FAQs address the impact of recent sanctions on the Islamic Republic of Iran Shipping Lines ("IRISL") and E-Sail Shipping Limited ("E-Sail"), announced by the U.S. Department of State under Executive Order (E.O.) 13382 and effective as of June 8, 2020.
FAQ 810 notes that while both IRISL and E-Sail were already targeted by sanctions under E.O. 13599, the new designations under E.O. 13382 will subject dealings with these two companies, as well as any entities owned 50 percent or more by them, to the prohibitions of the Weapons of Mass Destruction Proliferators Sanctions Regulations. In addition, non-U.S. persons that knowingly engage in certain transactions with the companies (or entities owned 50 percent or more by them) may face the imposition of secondary sanctions. FAQ 811 explains that, while U.S. sanctions generally permit the sale of agricultural commodities, food, medicine and medical devices to Iran by U.S. and non-U.S. persons, such authorizations generally do not apply to persons, like IRISL and E-Sail, sanctioned pursuant to E.O. 13599.
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