medical devices

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 Department of Treasury’s Office of Foreign Assets Control (OFAC) has announced new rules, which will take effect December 23, 2016, amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). The revised rules expand the scope of medical devices and agricultural commodities that may be exported or re-exported to Iran without specific authorization, pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA).