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ARTICLE · 20 JUNE 2016

OFAC Issues Clarifying FAQs for Iran Sanctions Regulation

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On June 8, 2016, US the Office of Foreign Assets Control (OFAC) issued several new frequently asked questions (FAQs) that provide further guidance regarding activities authorized by General License H (GLH), ..

United StatesInternational Law
Kenneth Nunnenkamp
Kenneth Nunnenkamp
Giovanna M. Cinelli
Giovanna M. Cinelli
Michael Zolandz
Michael Zolandz
Peter Feldman
Peter Feldman
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On June 8, 2016, US the Office of Foreign Assets Control (OFAC) issued several new frequently asked questions (FAQs) that provide further guidance regarding activities authorized by General License H (GLH), and address how to handle US personnel participating as board or management members of a foreign-owned or -controlled entity that is conducting business with or in Iran. Most of the FAQs confirm the commonly understood scope of activities under GLH, which issued on January 16, 2016, but OFAC addressed a few significant aspects in this new guidance. Some of the highlights of these new FAQs include:

  1. Confirmation that General License H authorizes the US entity that owns or controls a foreign entity to enact and amend the policies of both the US entity and the foreign entity to address the foreign entity's business with Iran. (K.18-19). Significantly, the FAQs state both that the foreign entity may establish a presence in Iran, and that the establishment of

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