McNabb Associates, P.C.
Global Criminal Defense

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IRAN

Q: What is the origin of the Iranian Transactions Regulations?
A: In 1987, President Reagan issued an import embargo on Iranian-origin goods and services as a result of Iran’s support for international terrorism and its aggressive actions against non-belligerent shipping in the Persian Gulf. In 1995, President Clinton prohibited U.S. involvement with petroleum development in Iran as a result of Iranian sponsorship of international terrorism and its active pursuit of weapons of mass destruction. But in 2000, sanctions were eased to allow U.S. persons to purchase and import carpets and food products from Iran.

Q: What are the current regulations on imports from Iran?
A: No one may import Iranian goods or services directly or indirectly except for: Gifts valued at $100 or less; Information or informational materials; Foodstuffs intended for human consumption that are classified under the Harmonized Tariff Schedule of the U.S.; and Carpets and other textile floor coverings and carpets used as wall hangings that are classified under the Harmonized Tariff Schedule of the U.S.

Q: What are the current regulations on exports from the U.S. to Iran?
A: Unless licensed by Treasury’s Office of Foreign Assets Control (OFAC), goods, technology, or services may not be exported, reexported, sold or supplied, directly or indirectly from the U.S. or by a U.S. person to Iran or the Iranian Government.

Q: Are there any restrictions on the activities of foreign subsidiaries of U.S. firms?
A: Yes, no U.S. person may approve or facilitate the entry into or performance of transactions or contracts with Iran by a foreign subsidiary of a U.S. firm that the U.S. person is precluded from performing directly.

Q: Are there any restrictions on personal communications, information or informational materials passing between the U.S. and Iran?
A: No. Receipt or transmission of postal, telegraphic, telephonic or other personal communications, which does not involve the transfer of anything of value, is permitted.

Q: Do any of the regulations affect foreign persons who import U.S. goods?
A: Yes, foreign persons are prohibited from reexporting sensitive U.S.-origin goods, technology or services to Iran or the Iranian Government.