Iran-related Designation and Designation update; Hostages and Wrongfully Detained U.S. Nationals Designations; Publication of Iran-related Frequently Asked Questions

The Office of Foreign Assets Control (OFAC) has published a press release to inform about new sanction measures and about the implementation of a new „humanitarian channel Quatar“ which aims to facilitate humanitarian aid for Iran while upholding stringent measures against money laundering and misuse. This channel does not remove existing U.S. sanctions on Iran, which remain in place due to Iran’s involvement in activities such as weapons proliferation and support for international terrorism.
Specifically, the Office added the former President of Iran to its Specially Designated Nationals and Blocked Persons List (SDN List) pursuant to Executive Order 14078) and altered the records of one entity. The affected parties are the following:
#### Person added to the sanctions list
AHMADINEJAD, Mahmoud (Arabic: محمود احمدی‌نژاد) (a.k.a. AHMADI NEJAD, Mahmoud; a.k.a. AHMADINEJAD, Mahmood; a.k.a. AHMADI-NEJAD, Mahmud; a.k.a. AHMADINEJHAD, Mahmoud; a.k.a. AHMADINEZHAD, Mahmoud; a.k.a. AHMEDINEJAD, Mahmud), Tehran, Iran; DOB 28 Oct 1956; POB Garmsar, Iran; nationality Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [IRAN] [HOSTAGES-EO14078] (Linked To: IRANIAN MINISTRY OF INTELLIGENCE AND SECURITY).
#### Modifications to the records of one entity
IRANIAN MINISTRY OF INTELLIGENCE AND SECURITY (a.k.a. VEZARAT-E ETTELA’AT VA AMNIAT-E KESHVAR; a.k.a. „MOIS“; a.k.a. „VEVAK“), bounded roughly by Sanati Street on the west, 30th Street on the south, and Iraqi Street on the east, Tehran, Iran; Ministry of Intelligence, Second Negarestan Street, Pasdaran Avenue, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Target Type Government Entity [SDGT] [SYRIA] [IFSR] [IRAN-HR] [HRIT-IR] [CYBER2]. -to- IRANIAN MINISTRY OF INTELLIGENCE AND SECURITY (a.k.a. VEZARAT-E ETTELA’AT VA AMNIAT-E KESHVAR; a.k.a. „MOIS“; a.k.a. „VEVAK“), bounded roughly by Sanati Street on the west, 30th Street on the south, and Iraqi Street on the east, Tehran, Iran; Ministry of Intelligence, Second Negarestan Street, Pasdaran Avenue, Tehran, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Target Type Government Entity [SDGT] [SYRIA] [IFSR] [IRAN-HR] [HRIT-IR] [CYBER2] [HOSTAGES-EO14078].
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Concurrently, OFAC published two frequently asked questions (FAQs) relating to the above noted „humanitarian channel Quatar“. The affected FAQs read as follows:
FAQ 1134. What is the humanitarian channel in Qatar?
The humanitarian channel in Qatar (HC) was established to further facilitate the flow of humanitarian assistance to the people of Iran consistent with the U.S. government’s longstanding support for humanitarian trade. Similar to humanitarian channels established under previous administrations, the HC is designed to support the Iranian people’s access to food, agricultural goods, medicine, and medical devices under stringent due diligence measures that guard against money laundering, misuse, and evasion of U.S. sanctions.
The HC offers a voluntary option for facilitating payments for humanitarian exports to Iran, but parties may continue to avail themselves of existing exceptions and authorizations to conduct humanitarian trade with Iran outside of the channel. The United States has long maintained broad exceptions and authorizations for the sale of food, agricultural commodities, medicine, and medical devices to Iran by U.S. and non-U.S. persons. OFAC’s Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran reflects longstanding regulations related to exports of humanitarian goods to Iran. These exceptions and authorizations are also clearly stated on the Iran Sanctions Program website maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control.
The HC has not and does not allow funds to be released to the Government of Iran or payments to Iranian companies. In partnership with the Government of Qatar and financial institutions operating the HC — all of which have committed to stringent due diligence measures — the United States will closely monitor the HC and will take appropriate action should Iran attempt to use these funds for purposes other than permitted humanitarian purchases. The HC does not lift any U.S. sanctions on Iran, and the U.S. government continues to impose sanctions on Iran’s malign activity, including in response to Iran’s weapons proliferation and its support for international terrorism.
FAQ 1135. How can companies participate in the humanitarian channel in Qatar to export humanitarian goods to Iran?
Financial institutions participating in the humanitarian channel in Qatar (HC) have received specific guidance from the U.S. government. Companies interested in participating in transactions under the HC should coordinate directly with the Qatari International Media Office at info@imo.gov.qa and should not hesitate to contact the OFAC Compliance Hotline with specific questions.
OFAC’s requirements related to humanitarian trade with Iran have not changed. Companies interested in participating in transactions pursuant to existing exceptions and authorizations for the conduct of humanitarian trade with Iran may continue to do so outside of the HC. For example, certain humanitarian transactions involving the Central Bank of Iran and the National Iranian Oil Company are permissible under General License 8A (see also FAQ 823). OFAC FAQ 828 and our Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran reflect OFAC’s longstanding regulations related to exports of humanitarian goods to Iran. Iranian financial institutions designated under Executive Order (E.O.) 13902 are subject to the exception in E.O. 13902 with respect to conducting or facilitating transactions for the provision (including any sale) of agricultural commodities, food, medicine, or medical devices to Iran.
U.S. persons and their owned or controlled foreign entities must continue to comply with the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), when conducting exports of humanitarian goods to Iran. Certain exports and sales of humanitarian goods to Iran are authorized pursuant to sections 560.530, 560.532, and 560.533 of the ITSR.
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Finally, OFAC published an accompanying press statement explaining the reasoning behind the sanctioning of former the President.