OFAC Updates List of Entities Owned or Controlled by the Government of Iran
The Treasury Department announced today that the Office of Foreign Assets Control (OFAC) has added the National Iranian Oil Company (a.k.a. NIOC), Naftiran Intertrade Company Ltd. (a.k.a. NICO), and Naftiran Intertrade Co. Sarl as entities owned or controlled by the Government of Iran to the Appendix (scroll down to Appendix A) of entities determined by OFAC to be owned or controlled by the Government of Iran.
This is the first time that OFAC has added non-financial institutions to the Appendix. Treasury's announcement indicated that "OFAC will continue to list both financial institutions and other entities that are determined to be owned or controlled by the Government of Iran."
While the prohibitions in OFAC's Iranian Transactions Regulations (ITRs) apply to all entities owned or controlled by the Government of Iran, Appendix A is intended to serve as a tool to assist U.S. persons in complying with ITRs. This is because most commercial and financial transactions with entities owned or controlled by the Government of Iran are prohibited, regardless of where such entities are located or incorporated. Most transactions with any branches or subsidiaries of these entities are also prohibited, regardless of where such branches or subsidiaries are located and incorporated.