OFAC issued three new FAQs and updated two existing FAQs on U.S. sanctions against Iran.

The new FAQs addressed changes made by Executive Order 13846 and General License K clarifying, respectively:

  • the ramifications of non-U.S. persons providing goods or services to non-Iranian persons sanctioned under section 3 of Executive Order 13846;

  • the types of activities that qualify as "maintenance" under General License K, authorizing the maintenance and wind-down of transactions involving COSCO Shipping Tanker (Dalian) Co., Ltd.; and

  • the conditions under which U.S. financial institutions can process transactions involving COSCO Shipping Tanker (Dalian) Co., Ltd.

OFAC also updated the FAQs regarding:

  • which insurance, reinsurance or underwriting activities are subject to sanctions under the Iran Freedom and Counter-Proliferation Act of 2012; and

  • the general non-applicability of sanctions to the corporate parent and affiliates of the COSCO Shipping Tanker (Dalian) Co., Ltd. and COSCO Shipping Tanker (Dalian) Seaman & Ship Management Co.