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Department of the Treasury in economic sanctions against foreign states dates to the War of 1812, when Secretary Albert Gallatin administered sanctions against Great Britain in retaliation for the impressment of American sailors. In 2014, OFAC reached a record $963 million settlement with the French bank BNP Paribas, which was a portion of an $8.9 billion penalty imposed in relation to the case as a whole. Sometimes described as one of the 'most powerful yet unknown' government agencies, OFAC was founded in 1950 and has the power to levy significant penalties against entities that defy its directives, including imposing fines, freezing assets, and barring parties from operating in the United States. While many of OFAC's targets are broadly set by the White House, most individual cases are developed as a result of investigations by OFAC's Office of Global Targeting (OGT). Treasury Department, OFAC operates under the Office of Terrorism and Financial Intelligence and is primarily composed of intelligence targeters and lawyers. Under Presidential national emergency powers, OFAC carries out its activities against foreign states as well as a variety of other organizations and individuals, like terrorist groups, deemed to be a threat to U.S. national security and foreign policy objectives.
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It administers and enforces economic and trade sanctions in support of U.S. The Office of Foreign Assets Control ( OFAC) is a financial intelligence and enforcement agency of the U.S. By issuing General License J-1, OFAC has started to provide its answer, as this particular condition was deleted from the license. Following the issuance of General License J, there was widespread speculation that OFAC would provide additional guidance regarding whether and how code-sharing agreements could be effectuated with Iran. The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has revoked Iran-related General Licenses H and I, which were issued in connection with the Joint Comprehensive Plan of Action (JCPOA). Law, Iran Sanctions, Legal Risk Management, Sanctions. FebruMassPoint PLLC Banking Law & Regulation, Doing Business in the United States, Extraterritorial U.S. Persons to Transact in Certain Inherited and Other Property in Iran. Since Mobile Phones are authorized for export on the Annex to General License D and specifically those categorized as 5A992.c, then an iPhone 5 may be exported to Iran for persona use under General License D.įiled Under: All About Immigration for Investors and Others, Business, International, Uncategorized Tagged With: 5A992.c, 5D992.OFAC Expanded General License for U.S. To illustrate, information on Apple’s public website provides ECCNs for its iPhone 5 as 5A992.c. But recently, effective with General License D, exports to Iran of software, hardware, and services related to “personal communications” for personal use is NLR - so long as each item is designated EAR99 or ECCN 5D922.c or as designated on the Annex to the General License D. Iran previously was on this “bad boy” list. This last remaining check is to verify the receiving country is not on the “bad boy” list of countries that give rise to an export or other license requirement. But be forewarned: this doesn’t mean the exporter needs no license! It simply means there is one final check required. EAR99, for example, indicates that the items are “NLR” – or no license required. Alternately, items may be so ubiquitous and “mass market” that it makes little sense to regulate their export since they are found all over the world readily. For example, items related to ballistics would be high-risk, so must be exported with great care to ensure the items do not fall into the hands of the wrong parties. Additionally, the Annex to General License D details EAR and ECCN designations by eleven categories.įor the uninitiated, EAR and ECCN nomenclature may be quite perplexing, but they are simply ways to categorize exportable items according to degree of risk.
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Department of Commerce pursuant to its Commerce Control List detailed on supplement No. Specifically, the designation must be either: (1) EAR99 pursuant to Export Administration Regulation or export control classification number (“ECCN”) 5D992.c by the U.S. To be exportable under OFAC General License D, software, hardware, and services must bear a specific categorization based upon the type of device, technology, and purpose.