Primary Sanctions
By contrast to the secondary sanctions, the so-called primary sanctions which are applicable to US persons as well as to US-owned or US-controlled foreign entities1 largely continue to apply. Those companies and individuals continue to be generally prohibited from conducting transactions with Iran.
However, OFAC issued “General License H” that allows US-owned or US-controlled foreign entities to engage in transactions with the Government of Iran or any person subject to the jurisdiction of the Government of Iran. The license is not limited to specific economic sectors or industries but includes certain requirements which transactions have to comply with, in particular (i) the direct or indirect export or re-export of goods, technology, or services from the US (without separate authorization from OFAC); (ii) any transfer of funds to, from, or through the US financial system; (iii) any individual or entity on the OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List) or on the Foreign Sanctions Evaders List or any activity that would be prohibited by non-Iran sanctions administered by OFAC if engaged in by a US person or in the US. Furthermore the US also permitted the following categories of US-Iranian trade: the sale of commercial passenger aircraft and related parts and services to Iran and the importation of Iranian-origin carpets and foodstuffs into the US, subject to OFAC licenses.
