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persons for transactions outside the United States and which threaten sanctions against foreign persons for sanctionable conduct, including engaging in certain business involving Iran). nexus and carry potential monetary penalties for violations) and “secondary” sanctions (which apply to non-U.S. sanctions are often categorized into “primary” sanctions (which apply to U.S. sanctions against Iran do not prevent Iranian companies and individuals from obtaining medical supplies and safety equipment necessary to fight the COVID-19 epidemic or endanger Iranian workers. The new FAQs continue OFAC’s recent efforts to ensure that U.S. These FAQs define the construction, mining, manufacturing, and textile sectors of the Iranian economy and clarify that OFAC will not view sales of humanitarian, safety, and sanitation-related goods/services to persons in Iran who are not Specially Designated Nationals (“ SDNs”) as operating in these sectors or transacting in goods or services used in connection with these sectors.
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Treasury Department’s Office of Foreign Assets Control (“ OFAC”) issued four new frequently asked questions (“ FAQs”) that define key terms used in secondary sanctions added to the Iran sanctions program earlier this year.