


Please see Frequently Asked Question 1002. persons are prohibited from engaging in direct or indirect transactions involving any Russia-related Directive 4 Entity. Pursuant to the Russia-related Sovereign Transactions Directive, U.S. This so-called “exit tax” is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, not authorized under GL 13D.

person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, Russia-related Directive 4 Entities) that would otherwise be prohibited by Russia-related Directive 4 under Executive Order 14024 (the Russia-related Sovereign Transactions Directive ), provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. persons, or entities owned or controlled, directly or indirectly, by a U.S. Please see Iran GL O for further details. As with all OFAC GLs, Iran GL O only authorizes against the authorities identified in the GL and contains certain conditions. Persons unable to complete authorized transactions involving the blocked vessels specified in Iran GL O before its expiration are encouraged to seek guidance from OFAC in advance of that date. Iran GL O is in effect until 12:01 eastern daylight time, June 30, 2023. persons if such transactions would be authorized for U.S. financial institutions may also process transactions conducted by non-U.S. The offloading of Iranian-origin petroleum, petroleum products, or petrochemical products, regardless of the situation, is not authorized pursuant to Iran GL O and requires a specific license from OFAC. This narrower authorization under the ITSR allows only transactions ordinarily incident and necessary to certain limited safety and environmental situations: the safe docking and anchoring of any of the blocked vessels in port the preservation of the health and safety of the crew or emergency repairs or environmental mitigation or protection activities. Accordingly, for blocked vessels containing Iranian-origin merchandise or involving persons ordinarily resident in Iran, Iran GL O provides a separate, more limited authorization under the ITSR. persons are separately prohibited, pursuant to the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), from engaging in most Iran-related transactions. This includes, among other activities, the unloading of any non-Iranian merchandise loaded on the blocked vessel as of March 2, 2023, provided there is no other sanctions nexus. persons to wind down all transactions otherwise prohibited by section 5 of Executive Order 13846 involving any vessel blocked as part of the Madesignation (“blocked vessels”), subject to certain conditions.
