INTRODUCTION
The assets of the Government of Iran in the United
States were blocked in accordance with the International
Emergency Economic Powers Act ("IEEPA") on November
14, 1979, following the seizure of the American Embassy
in Teheran and the taking of U.S. diplomats as hostages.
Under the Iranian Assets Control Regulations (Title
31 Part 535 of the U.S. Code of Federal Regulations),
some US$12 billion in Iranian Government bank deposits,
gold, and other properties were frozen, including $5.6 billion
in deposits and securities held by overseas branches of
U.S. banks. The assets freeze was eventually expanded to
a full trade embargo, which remained in effect until
the Algiers Accords were signed with Iran on January
19, 1981. Pursuant to the Accords, most Iranian assets
in the United States were unblocked and the trade embargo
was lifted. The U.S. Government also canceled any attachments
that U.S. parties had secured against Iranian assets
in the United States, so that the assets could be returned
to Iran or transferred to escrow accounts in third countries
pursuant to the Accords. This action was upheld by the
Supreme Court in 1981 in Dames & Moore v. Regan.
Although greatly modified in scope, the old Iranian Assets
Control Regulations remain in effect. Many U.S. nationals
have claims against Iran or Iranian entities for products
shipped or services rendered before the onset of the
1979 embargo or for losses sustained in Iran due to
expropriation during that time. These claims are still
being litigated in the Iran-United States Claims Tribunal
at The Hague established under the Algiers Accords.
Certain assets related to these claims remain blocked in
the United States consisting mainly of military and
dual-use property.
As a result of Iran's continued support for international
terrorism and its aggressive actions against non-belligerent
shipping in the Persian Gulf, President Reagan, on
October 29, 1987, issued Executive Order 12613 imposing
a new import embargo on Iranian- origin goods and services.
Section 505 of the International Security and Development
Cooperation Act of 1985 (ISDCA) was utilized as the
statutory authority for the embargo which gave rise to
the Iranian Transactions Regulations (Title 31 Part 560 of the
U.S. Code of Federal Regulations).
Effective March 16, 1995, as a result of Iranian sponsorship
of international terrorism and its active pursuit of
weapons of mass destruction, President Clinton issued
Executive Order 12957 prohibiting U.S. involvement
with petroleum development in Iran. On May 6, 1995, he signed
Executive Order 12959, pursuant to IEEPA as well as
the ISDCA, substantially tightening sanctions against Iran.
Corporate criminal penalties for violations of the Iranian
Transactions Regulations can range up to $500,000, with
individual penalties of up to $250,000 and 10 years in jail.
Civil penalties of up to $10,000 may also be imposed
administratively.
This fact sheet provides general information about the
Iranian sanctions program under the Iranian Transaction
Regulations, which incorporate the new sanctions imposed
by Executive Order 12957 and 12959. The sanctions are
administered by the U.S. Treasury Department's Office
of Foreign Assets Control ("OFAC").
Iranian
Transactions Regulations - 31 C.F.R. Part 560
o BUYING FROM IRAN -
Other than gifts valued at $100 or less and Iranian
origin publications and materials imported for news publications
or news broadcast dissemination, goods or services of Iranian
origin may not be imported into the United States, either
directly or through third countries. U.S. persons are prohibited
from providing financing for prohibited import transactions.
o SELLING TO IRAN -
In general, goods, technology (including technical
data or other information subject to Export Administration
Regulations), or services may not be exported from the United
States to Iran or the Government of Iran. There is an exception
for feed grains, rice, wheat, cotton, peanuts, tobacco,
dairy products, and oilseeds, including vegetable oil (all
of which are called "agricultural commodities"
in the Regulations), provided that the underlying trade
contract for their exportation was in place prior to
May 7, 1995 and delivery occurs prior to February 2, 1996
pursuant to the terms of the original contract. Donations of
articles intended to relieve human suffering (such as food,clothing,
and medicine), gifts valued at $100 or less, and "informational
materials" are permitted. "Informational materials"
are defined to mean publications, films, posters, phonograph
records, photographs, microfilms, microfiche, tapes, compact
disks, CD ROMs, artworks, and news wire feeds, although
certain Commerce Department restrictions still apply
as to some of those materials.
To be considered informational, artworks must be classified
under chapter subheadings 9701, 9702, or 9703 of the
Harmonized Tariff Schedule of the United States.
Services provided in a third country by a U.S. individual
ordinarily resident outside the United States are not considered
to be exported from the U.S., but services provided
by the foreign branch of a U.S. incorporated firm are
considered to be exported from the U.S. home office.
The reexportation to Iran or the Government of Iran of
any goods or technology exported from the United States,
the exportation of which to Iran was subject to export
license application requirements under any United States
regulations in effect prior to May 6, 1995, is prohibited
unless the reexportation is of goods that have been
substantially transformed outside the U.S. or incorporated
into another product outside the U.S. and constitute less
than 10% by value of that product exported from a third
country. Inventory sales identified to a specific contract
involving Iran are considered transshipments and are prohibited.
o DEALING IN IRANIAN ORIGIN GOODS OR SERVICES -
U.S. persons,including foreign branches of U.S. banks and
trading companies, are prohibited from engaging in any transactions,
including purchase, sale, transportation, swap, financing, or
brokering transactions related to goods or services
of Iranian origin or owned or controlled by the Government
of Iran.
Services provided in the United States by an Iranian national
resident in the United States are not considered services
of Iranian origin.
These prohibitions apply to transactions by United States
persons in locations outside the United States with respect
to goods or services which the United States person
knows, or has reason to know, are of Iranian origin or are owned
or controlled by the Government of Iran; U.S. persons
may not import such goods or services into or export
them from foreign locations. A U.S. person may, however, engage
in transactions in third countries necessary to sell, dispose
of, store, or maintain goods located in a third country
which were legally acquired by that U.S. person prior to
May 7, 1995 on the condition that the transactions do not
result in an importation into the United States.
o FINANCIAL DEALINGS WITH IRAN -
New investments by U.S. persons, including commitments
of funds or other assets, loans or any other extensions of credit,
in Iran or in property (including entities) owned or
controlled by the Government of Iran are prohibited. For
your information, Appendix A contains a list of banks owned
or controlled by the Government of Iran. While U.S.
persons may continue to charge fees and accrue interest
on existing Iranian loans, a specific license must
be obtained to reschedule or otherwise extend the maturities
of existing loans.
o LETTERS OF CREDIT -
Letters of credit and other financing arrangements
with respect to trade contracts in force as of May 6, 1995
may be performed pursuant to their terms provided that the
underlying trade transaction was completed prior to June
6, 1995 (February 2, 1996 for "agricultural commodities"
as specified above) or as specifically licensed by
the Office of Foreign Assets Control. Standby letters
of credit that serve as performance guarantees for
services rendered after June 6, 1995 cannot be renewed
and payment may not be made after that date without authorization
by OFAC.
o OTHER BANKING SERVICES -
U.S. banks, including foreign branches, are prohibited
from servicing accounts of the Government of Iran, including
banks owned or controlled by the Government of Iran (as
in Appendix A) or persons in Iran. However, they are authorized
to pay interest, deduct reasonable and customary service
charges,process transfers related to exempt transactions, such
as the exportation of information or informational
material, a travel-related remittance, or a payment for the
shipment of a donation of articles to relieve human
suffering or, at the request of an account holder,
effect a lump sum closure of an account by payment to
its owner. They may not otherwise directly credit or debit
Iranian accounts.
U.S. banks may handle "U-turn" transactions--cover
payments involving Iran that are by order of a third
country bank for payment to another third country bank
provided they do not directly credit or debit an Iranian
account. They are also permitted to handle non-commercial
family remittances involving Iran, provided the transfers
are routed to or from non-U.S. non-Iranian offshore banks.
U.S. banks initiating or receiving payment orders involving
Iran on behalf of customers must determine prior to
processing such payments that they do not involve transactions
prohibited by the Iranian Transactions Regulations.
o TRAVEL -
All transactions ordinarily incident to travel to or
from Iran, including the importation of accompanied baggage
for strictly personal use, payment of maintenance and
living expenses and acquisition of goods or services
for personal use are permitted. The use of currency
drafts, charge, debit or credit cards in Iran is not
permitted.
o OVERFLIGHTS PAYMENTS -
Payments to Iran for services rendered by the
Government of Iran in connection with the overflight of Iran
or emergency landing in Iran of aircraft owned by United
States persons or registered in the U.S. are authorized.
o PERSONAL COMMUNICATIONS, INFORMATION AND INFORMATIONAL
MATERIALS
The receipt or transmission of postal, telegraphic, telephonic
or other personal communications, which does not involve the
transfer of anything of value, between the United States
and Iran is authorized. The exportation from the United
States to Iran of information and informational materials,
whether commercial or otherwise, regardless of format
or medium of transmission, and any transaction of common
carriers incident to such exportation is authorized.
o TRANSACTIONS INVOLVING U.S. AFFILIATES-
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.
o IRANIAN PETROLEUM INDUSTRY-
U.S. persons may not trade in Iranian oil or petroleum
products refined in Iran, nor may they finance such
trading. Similarly, U.S. persons may not perform services,
including financing services, or supply goods or technology,
that would benefit the Iranian oil industry.
APPENDIX A - BANKS OWNED OR CONTROLLED
BY THE GOVERNMENT OF IRAN
AGRICULTURAL COOPERATIVE BANK OF IRAN (a.k.a. BANK TAAVON
KESHAVARZI IRAN), No. 129 Patrice Lumumba Street, Jalal-Al-Ahmad
Expressway, P.O. Box 14155/6395, Tehran, Iran
AGRICULTURAL DEVELOPMENT BANK OF IRAN (a.k.a. BANK JOSIAIYI
KESHAHVARZI), Farahzad Expressway, Tehran, Iran.
BANK JOSIAIYI KESHAHVARZI (a.k.a. AGRICULTURAL DEVELOPMENT
BANK OF IRAN), Farahzad Expressway, Tehran, Iran.
BANK MARKAZI JOMHOURI ISLAMI IRAN (a.k.a. THE CENTRAL BANK
OF IRAN), Ferdowsi Avenue, P.O. Box 11365-8551, Tehran,
Iran.
BANK MASKAN (a.k.a. HOUSING BANK (of Iran)), Ferdowsi St.,
Tehran, Iran
BANK MELLAT, Park Shahr, Varzesh Avenue, P.O. Box 11365/5964,
Tehran, Iran, and all offices worldwide, including, but
not limited to:
BANK MELLAT (Branch), Ziya Gokalp Bulvari No. 12, Kizilay,
Ankara, Turkey
BANK MELLAT (Branch), Binbir Cicek Sokak, Buyukdere Caddesi,
P.O. Box 67, Levant, Istanbul, Turkey
BANK MELLAT (Branch), 48 Gresham Street, London EC2V 7AX,
England
BANK MELLI, P.O. Box 11365-171, Ferdowsi Avenue, Tehran,
Iran, and all offices worldwide, including, but not
limited to:
BANK MELLI (Branch), 4 Moorgate, London EC2R 6AL, England
BANK MELLI (Branch), Schadowplatz 12, 4000 Dusseldorf
1, Germany
BANK MELLI (Branch), Friedenstrasse 4, P.O. Box 160 154,
6000 Frankfurt am Main, Germany
BANK MELLI (Branch), P.O. Box 112129, Holzbruecke 2,
2000 Hamburg 11, Germany
BANK MELLI (Branch), Odeonsplatz 18, 8000 Munich 22,
Germany
BANK MELLI (Branch), 43 Avenue Montaigne, 75008 Paris,
France
BANK MELLI (Branch), 601 Gloucester Tower, The Landmark,
11 Pedder Street, P.O. Box 720, Hong Kong
BANK MELLI (Representative Office), 333 New Tokyo Building,
3-1 Marunouchi, 3-chome, Chiyoda-ku, Tokyo, Japan
BANK MELLI (Agency), 818 Wilshire Boulevard, Los Angeles,
California 90017, U.S.A
BANK MELLI (Agency), 767 Fifth Avenue, 44th Floor, New
York, New York 10153, U.S.A
BANK MELLI (Representative Office), Smolensky Boulevard
22/14, Kv. S., Moscow, Russia
BANK MELLI (Branch), Flat No. 1, First Floor, 8 Al Sad
El-Aaly, Dokki, P.O. Box 2654, Cairo, Egypt
BANK MELLI (Branch), Ben Yas Street, P.O. Box No. 1894,
Riga Deira, Dubai, U.A.E.
BANK MELLI (Branch), P.O. Box 2656, Shaikha Maryam Building,
Liwa Street, Abu Dhabi, U.A.E
BANK MELLI (Branch), B.P.O. Box 1888, Clock Tower, Industrial
Road, Al-Ain Club Building in from Emertel Al Ain,
Al Ain, Abu Dhabi, U.A.E.
BANK MELLI (Branch), P.O. Box 1894, Riqa, Ban Yas Street,
Deira, Dubai, U.A.E.
BANK MELLI (Branch), Mohd-Habib Building, Al-Fahidi Street,
P.O. Box 3093, Bur Dubai, Dubai, U.A.E.
BANK MELLI (Branch), P.O. Box 248, Fujairah, U.A.E.
BANK MELLI (Branch), Sami Sagar Building Oman Street
Al-Nakheel, P.O. Box 5270, Ras-Al Khaimah, U.A.E.
BANK MELLI (Branch), P.O. Box 459, Al Bory Street, Sharjah,
U.A.E.
BANK MELLI (Branch), P.O. Box 785, Government Road, Shaikh
Mubarak Building, Manama, Bahrain.
BANK MELLI (Branch), P.O. Box 23309, Shaikh Salman Street,
Road No. 1129, Muharraq 211, Bahrain.
BANK MELLI (Branch), P.O. Box 5643, Mossa Abdul Rehman
Hassan Building, 238 Al Burj St., Ruwi, Muscat, Oman.
BANK OF INDUSTRY AND MINE (of Iran) (a.k.a. BANK SANAT
VA MADAN), Hafez Avenue, P.O. Box 11365/4978, Tehran,
Iran.
BANK REFAH KARGARAN (a.k.a. WORKERS WELFARE BANK (of Iran)),
Moffettah No. 125, P.O. Box 15815 1866, Tehran, Iran.
BANK SADERAT IRAN, Bank Saderat Tower, P.O. Box 15745-631,
Somayeh Street, Tehran, Iran, and all offices worldwide,
including, but not limited to:
BANK SADERAT IRAN (Branch), Hamdam Street, Airport Road
Intersection, P.O. Box 700, Abu Dhabi, U.A.E.
BANK SADERAT IRAN (Branch), Al-Am Road, P.O. Box 1140,
Al Ein, Abu Dhabi, U.A.E.
BANK SADERAT IRAN (Branch), Liwara Street, P.O. Box 16,
Ajman, U.A.E.
BANK SADERAT IRAN (Branch), 3rd Floor Dom Dasaf Building,
Mejloka Street 7A, Ashkhabad, Turkmenistan.
BANK SADERAT IRAN (Branch), 25-29 Panepistimiou Street,
P.O. Box 4308, GR-10210, Athens 10672, Greece.
BANK SADERAT IRAN (Branch), Imam Ali Street, Sahat Yaghi,
Ras Elain-Alektisad Building 2nd Floor, Baalbeck,
Lebanon.
BANK SADERAT IRAN (Branch and Offshore Banking Unit),
106 Government Road, P.O. Box 825, Manama Town 316,
Bahrain.
BANK SADERAT IRAN (Branch), Hamra Pavillion Street, Savvagh
and
Daaboul Building 1st Floor, P.O. Box 113-6717, Beirut,
Lebanon .
BANK SADERAT IRAN (Branch), Alghobairi Boulevard, Beirut,
Lebanon.
BANK SADERAT IRAN (Branch), 28 Sherif Street, P.O. Box
462, Cairo, Egypt.
BANK SADERAT IRAN (Branch), Old Ben-Ghanem Street (next
to God Market), P.O. Box 2256, Doha, Qatar.
BANK SADERAT IRAN (Branch), Almaktoum Road, P.O. Box
4182, Deira, Dubai, U.A.E.
BANK SADERAT IRAN (Branch), Bazar Murshid, P.O. Box 4182,
Deira, Dubai, U.A.E.
BANK SADERAT IRAN (Branch), Alfahid Road, P.O. Box 4182,
Bur Dubai, Dubai, U.A.E.
BANK SADERAT IRAN (Branch), Sherea Shekikh Zayad Street,
P.O. Box 55, Fujairah, U.A.E.
BANK SADERAT IRAN (Branch), Wilhelm Leuschner Strasse
41, P.O. Box 160151, W-6000 Frankfurt am Main, Germany.
BANK SADERAT IRAN (Branch), P.O. Box 112227, Hopfenhof
Passage, Kleiner Bustah 6-10, W-2000 Hamburg 11,
Germany.
BANK SADERAT IRAN (Branch), Lothbury, London EC2R 7HD,
England .
BANK SADERAT IRAN (Representative Office), 707 Wilshire
Boulevard, Suite 4880, Los Angeles, California 90017,
U.S.A.
BANK SADERAT IRAN (Agency), 375 Park Avenue, New York,
New York 10152, U.S.A.
BANK SADERAT IRAN (Branch), P.O. Box 4269, Mutrah, Muscat,
Oman.
BANK SADERAT IRAN (Branch), 16 rue de la Paix, Paris
2eme, 75002 Paris, France.
BANK SADERAT IRAN (Branch), Alaroba Road, P.O. Box 316,
Sharjah, U.A.E.
BANK SANAT VA MADAN (a.k.a. BANK OF INDUSTRY AND MINE (of
Iran)), Hafez Avenue, P.O. Box 11365/4978, Tehran,
Iran.
BANK SEPAH, Emam Khomeini Square, P.O. Box 11364, Tehran,
Iran, and all office worldwide, including, but not
limited to:
BANK SEPAH (Branch), Muenchener Strasse 49, P.O. Box
10 03 47, W- 6000 Frankfurt am Main 1, Germany.
BANK SEPAH (Branch), 5/7 Eastcheap, EC3M 1JT London,
England.
BANK SEPAH (Branch), 650 Fifth Avenue, New York, New
York 10019, U.S.A.
BANK SEPAH (Branch), 17 Place Vendome, 75001 Paris, France.
BANK SEPAH (Branch), Via Barberini 50, 00187 Rome, Italy.
BANK SEPAH (Representative Office), Ufficio di Rappresentan
Za, Via Ugo Foscolo 1, 20121 Milan, Italy.
BANK TAAVON KESHAVARZI IRAN (a.k.a. AGRICULTURAL COOPERATIVE
BANK OF IRAN) No. 129 Patrice Lumumba Street, Jalal-Al-Ahmad
Expressway, P.O. Box 14155/6395, Tehran, Iran.
BANK TEJARAT, 130 Taleghani Avenue, Nejatoullahie, P.O.
Box 11365- 5416, Tehran, Iran, and all offices worldwide,
including, but not limited to:
BANK TEJARAT (Branch), 6/8 Clements Lane, London EC4N
7AP, England.
BANK TEJARAT (Branch), 44 Avenue des Champs Elysees,
75008 Paris, France.
DEUTSCH-IRANISCHE HANDELSBANK AG (n.k.a. EUROPAEISCH-IRANISCHE
HANDELSBANK AG) Depenau 2, W-2000 Hamburg 1, Germany, and
all offices worldwide, including, but not limited to:
DEUTSCH-IRANISCHE HANDELSBANK AG (n.k.a. EUROPAEISCH-IRANISCHE
HANDELSBANK AG) (Representative Office), 23 Argentine Square,
Beihaghi Bulvard, P.O. Box 15815/1787, Tehran 15148, Iran.
EUROPAEISCH-IRANISCHE HANDELSBANK AG (f.k.a. DEUTSCH-IRANISCHE
HANDELSBANK AG) Depenau 2, W-2000 Hamburg 1, Germany, and
all offices worldwide, including, but not limited to:
EUROPAEISCH-IRANISCHE HANDELSBANK AG (f.k.a. DEUTSCH-IRANISCHE
HANDELSBANK AG) (Representative Office), 23 Argentine
Square,
Beihaghi Bulvard, P.O. Box 15815/1787, Tehran 15148,
Iran .
HOUSING BANK (of Iran) (a.k.a. BANK MASKAN), Ferdowsi St.,
Tehran,
Iran.
IRAN OVERSEAS INVESTMENT BANK LIMITED (f.k.a. IRAN OVERSEAS
INVESTMENT CORPORATION LIMITED), 120 Moorgate, London EC2M
6TS, England, and all offices worldwide, including,
but not limited to:
IRAN OVERSEAS INVESTMENT BANK LIMITED (Representative
Office), 1137
Avenue Vali Asr off Park-e-SAll, P.O. Box 15115/531,
Tehran, Iran.
IRAN OVERSEAS INVESTMENT BANK LIMITED (Agency), Suite
3c Olympia
House, 61/63 Dame Street, Dublin 2, Ireland.
IRAN OVERSEAS INVESTMENT BANK LIMITED (Agency), Improgetti,
Via
Germanico 24, 00192 Rome, Italy.
IRAN OVERSEAS TRADING COMPANY LIMITED (Subsidiary), 120
Moorgate,
London EC2M 6TS, England.
IRAN OVERSEAS INVESTMENT CORPORATION LIMITED (n.k.a.
IRAN OVERSEAS
INVESTMENT BANK LIMITED), 120 Moorgate, London EC2M 6TS,
England.
THE CENTRAL BANK OF IRAN (a.k.a. BANK MARKAZI JOMHOURI
ISLAMI IRAN), Ferdowsi Avenue, P.O. Box 11365-8551,
Tehran, Iran.
WORKERS WELFARE BANK (of Iran) (a.k.a. BANK REFAH KARGARAN),
Moffettah No. 125, P.O. Box 15815 1866, Tehran, Iran.
The Treasury Department's Office of Foreign Assets Control
also administers sanctions programs involving Libya,
Iraq, the Federal Republic of Yugoslavia (Serbia and
Montenegro) and Bosnian Serb- controlled areas of the
Republic of Bosnia and Herzegovina, Cuba, the National
Union for the Total Independence of Angola (UNITA), North
Korea, Syria, Sudan, Terrorists who threaten to disrupt the
Middle East peace process, and international Narcotics Traffickers.
It has certain residual authority with regard to sanctions
against Cambodia. For additional information about
these programs or about the Iranian sanctions programs,
please contact the:
OFFICE OF FOREIGN ASSETS CONTROL
U.S. Department of the Treasury
Washington, D.C. 20220
(202) 622-2520