On 23 September 2014, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a new Frequently Asked Question (“FAQ”) on its website regarding payments to Iranian civil aviation authorities for overflights of Iran or emergency landings in Iran. Specifically, OFAC stated that such payments would not be sanctionable under US law if the relevant aircraft is owned by a non-US person and registered outside the United States, provided that the relevant transactions do not involve persons on the Specially Designated Nationals and Blocked Persons List (“SDN List”). The transactions remain permissible even if a political subdivision, agency or instrumentality of the Government of Iran or an Iranian depository institution is involved, provided such entities are not on the SDN List.

New FAQ #417