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The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has taken two unrelated sanctions actions against Iran over the past several days:

SDN Designations in Response to Ballistic Missiles Tests

Effective February 3, 2017, OFAC imposed sanctions against 13 individuals and 12 entities with ties to Iran’s ballistic missile program. OFAC added these individuals and entities to its list of Specially Designated Nationals (the “SDN list”) freezing all  of their assets held in the U.S. and prohibiting persons subject to U.S. jurisdiction from engaging in trade with the sanctioned individuals and entities. These sanctions also apply to non-U.S. persons on a secondary basis. In a press release, OFAC Acting Director John E. Smith stated “Iran’s continued support for terrorism and development of its ballistic missile program poses a threat to the region, to our partners worldwide, and to the United States” and also added “We will continue to actively apply all available tools, including financial sanctions, to address this behavior.”

The individuals and entities added to the SDN list in the action include:

  • Abdollah Asgharzadeh and his associate Tenny Darian, who have previously procured controlled and dual-use technology to support Iranian ballistic missile agencies;
  • East Star Company and Ofog Sabze Darya Company, which are two Iranian companies that have assisted in transporting missile-related technology to Iran;
  • Chinese companies Cosailing Business Trading Company and Ningbo New Century Import and Export Company, Ltd. and several of their brokers, who have procured goods and services, arranged transport and providing financial support to Iran’s missile program; and
  • Ali Sharifi, who has procured aviation spare parts and other sensitive items from Middle Eastern and Chinese suppliers for use in Iran’s missile program.

New Licensing Requirements for Medical Device Exports and Re-Exports to Iran

As previously reported here, OFAC recently amended the Iranian Transactions Sanctions Regulations, 31 C.F.R. part 560 (the “ITSR”) to authorize exports of a wider variety of medical equipment items to Iran by expanding the existing general license under §560.530(a)(3) of the ITSR. However, OFAC also maintains a “List of Medical Devices Requiring Specific Authorization” which are excluded from the §560.530(a)(3) general license. OFAC recently amended the ITSR in order to update and clarify the scope of the medical devices listed on the “List of Medical Devices Requiring Specific Authorization”.

Following this amendment, exports or reexports of medical devices listed on the “List of Medical Devices Requiring Specific Authorization” to Iran continue to require specific licenses from OFAC. Prospective exporters and/or reexporters would also need to obtain additional specific licenses for any training services, replacement parts or software to be exported or reexported to Iran in connection with these medical devices.

Outlook Going Forward

Husch Blackwell LLP’ s export controls and sanctions compliance team continues to monitor closely any export controls and sanctions related developments. Please contact Cortney Morgan, Linda Tiller or Grant Leach if you have any compliance questions related to the Iran sanctions or any other U.S. sanctions programs.