U.S. sanctions regarding trade with Iran, new FAQ

Updated “frequently asked questions” (FAQs) concerning sanctions imposed on trade with Iran

Updated frequently asked questions (FAQs) concerning sanctions imposed on trade with Iran

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today updated a set of “frequently asked questions” (FAQs) concerning sanctions imposed on trade with Iran.

The Iran-related FAQs now include new FAQ 932 (text provided below, hyperlinks omitted).

932. Do U.S. sanctions prohibit U.S. persons from visiting, or making donations to, the Imam Reza Holy Shrine in Mashhad, Iran? 

URGENT NOTE:  The U.S. Department of State cautions against any travel by U.S. persons to Iran. The Department of State has issued a Level Four Travel Advisory (Do Not Travel) for Iran due to the risk of kidnapping, arbitrary arrest, and detention of U.S. citizens.  See additional guidance available at https://travel.state.gov/content/travel/en/traveladvisories/traveladvisories/iran-travel-advisory.html. 

Transactions ordinarily incident to travel to or from Iran by U.S. persons fall within an exemption under the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560, and therefore generally are not prohibited.  See, e.g., 31 CFR. § 560.210(d).  Exempt transactions include religious pilgrimages by U.S. persons to the Imam Reza Holy Shrine and the acquisition of goods or services for personal use while traveling.  Furthermore, donations of articles, such as food, clothing, and medicine, by U.S. persons to the Imam Reza Holy Shrine intended to be used to alleviate human suffering also fall within an exemption and therefore generally are not prohibited under the ITSR.

However, U.S. persons may be prohibited from engaging in certain transactions involving persons blocked under sanctions programs or authorities outside the scope of the ITSR, such as Astan Quds Razavi (AQR) and its subsidiary, the Holy Shrine Organization, which oversees the Imam Reza Holy Shrine.  AQR was designated and added to OFAC’s Specially Designated Nationals and Blocked Persons List on January 13, 2021 pursuant to Executive Order (E.O.) 13876 for being owned or controlled by the Supreme Leader of Iran.  The Holy Shrine Organization is also considered blocked under E.O. 13876 pursuant to OFAC’s 50 Percent Rule to the extent it is 50 percent or more owned by AQR.  More information about OFAC’s 50 Percent Rule is available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/401.  U.S. persons are advised to act with caution when considering transactions or activities involving AQR or the Holy Shrine Organization. 

Those seeking additional guidance on transactions and activities involving the Imam Reza Holy Shrine may contact OFAC’s Sanctions Compliance and Evaluation Division by email at:  OFAC_Feedback@treasury.gov or may request a specific license or interpretive guidance from OFAC’s Licensing Division online at https://licensing.ofac.treas.gov/Apply/Introduction.aspx. 

September 30, 2021

 

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Doug Zuvich
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Andy Siciliano
Partner and National Practice Leader
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E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
Principal
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
Principal
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E: christopheryoung@kpmg.com

Gisele Belotto
Managing Director
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E: gbelotto@kpmg.com

George Zaharatos
Principal
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E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
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E: adoornaert@kpmg.com

Jessica Libby
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E: jlibby@kpmg.com

 

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