Iran

  • MED DEVICES TO IRAN

    QUESTION: A US registered company with manufacturing facilities overseas wishes to ship medical devices from the foreign manufacturing facility to Iran –        The devices are not on the “List of Medical Devices Requiring Specific Authorization” –        Devices are not US originating, but they may contain some US parts –        Corporate HQ is in the US, […]

  • FOREIGN SUB SALES TO IRAN

    QUESTION: If we have a US owned business in China that sells to a China company who then sells to Iran, now that General License H is in the wind down period, soon to be gone, can the US company be held liable for this secondary transaction between a China company and Iran? ========== Answers: […]

  • HYPOTHETICAL TO IRAN

    QUESTION: Looking for recommendations and suggestions on how to respond to this hypothetical scenario:   1) We are a US company that manufactures US product. 2) We sell to a Turkish Distributor 3) We are advised by an anonymous source that this Turkish distributor is selling goods to a Turkish company that is owned by […]

  • EAR99 ITEM TO IRAN

    QUESTION: According to EAR 742.8, it appears EAR99 items are allowed to export to Iran if the end use or end user is not mentioned in the regulation or found as a restricted party. In addition to, if the commodity is not noted in Part 746.7. However, I am not too sure about OFAC 560.201.205? […]

  • MEDICAL DEVICE TO IRAN

    QUESTION: My company is inquiring whether they can ship a U.S. medical device to a medical trade show in Saudi Arabia where it will be picked up by an Iranian customer. The Iranian customer will then take the medical device back to Iran. I am aware that medical devices can be shipped to Iran under […]

  • SHIPPING TO IRANIAN OWNED COMPANY

    QUESTION: Our sales team has asked if we can export a US made product to a non-embargoed country.  The issue is the company in in this non-embargoed country is owned by an Iranian company.   I’ve plan to make the following request, or ask the following questions of the sale team:   1) Please provide […]

  • FOREIGN PARTNER SHIPPING TO IRAN

    QUESTION: My US company has a 50% ownership of a French company.  This French company has a manufacturing plant in the UAE, which exports to Iran.  Are there any legal concerns for us for having part ownership in this foreign company?  The product is EAR 99 and has no US components.  What about if the […]

  • ASIA-PAC TO IRAN SHIPMENTS

    QUESTION: We have been asked to supply to an entity in Iran products out of one of our Southeast Asia countries. I have reviewed General License H and it appears that the transaction as outlined does not violate OFAC sanctions against Iran.  General License H only applies to foreign entities owned or controlled by a […]

  • ENERGY TRANSACTIONS WITH IRAN

    QUESTION: I am looking at the regulations for the SEC Reporting requirements related to transactions with Iran’s energy sector. It is my understanding that although General License H allows foreign subsidiaries to do business in Iran (subject to the license requirements), the SEC requirements (Section 13(r) of the Securities Exchange Act) require a disclosure if […]

  • FOREIGN ITEM TO IRAN

    Question: US Company exporter knows 2 FACTS: 1)   The part /component you export from the USA will be incorporated into a foreign origin item NOT subject to the EAR (i.e. beneath de minimus) 2)   The foreign end item (that is not subject to the EAR) will be exported to Iran. Is this OK, since the […]