Trade Implications between the US and Iran – OFAC Licensed Shipments to Iran

How to Ship to Iran from the US

map-of-iranNavigating through US Sanctions regulations can be a dizzying task, especially when it involves international trade, logistics and export compliance. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign states, organizations, and individuals. With the recent nuclear deal between Iran, the United States, Britain, France, Germany Russia and China, an overview and update relating to the international shipping and compliance to Iran of OFAC licensed cargo would be relevant at this time. No one knows if a final deal will actually happen between the US and Iran, but manufacturers, producers, exporters, and traders must be prepared in case sanctions get better or worse, because the implications for trade are far reaching. This post also applies to anyone who is currently exporting to Iran or wants to export to Iran under current sanctions using an OFAC license.
the-us-department-of-the-treasury-ofac-licenses-for-iranThere are two areas of Sanctions regulations with relation to Iran. One is from the US Department of Treasury’s Office of Foreign Assets Control (OFAC). The other is with the Bureau of Industry and Security (BIS). Please click on their respective links to learn a little more about what each organization does with relation to export compliance for Iran shipments. Whether you want to ship to the seaports of Bandar Abbas (Shahid Rajaee terminal), Bandar Bushehr or airports such as Tehran Imam Khomeini International (IKA), Mashhad International Airport (MHD), Shiraz International Airport (SYZ), or Isfahan International Airport (IFN), we have the carriers and logistics solutions to assist your company.
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This post focuses on OFAC Sanctions Regulations for Exports and Reexports to Iran. You can view OFAC’s Iran page by clicking here. You can call this a “How to ship from US to Iran” or “How to Export from US to Iran.” Let’s start with some basic questions:

Some Questions and Answers:

 

 

Q: What is an OFAC General License?

A: A general license authorizes a particular type of transaction for a class of persons without the need to apply for a license. (i.e. If your cargo falls under a General License, you do not need to apply for any license, anyone can ship using the General License, but your freight forwarder must know how to declare your shipment to US Customs to avoid issues).

 

Q: What is an OFAC Specific License?

A: A specific license is a written document issued by OFAC to a particular person or entity, authorizing a particular transaction in response to a written license application. (OFAC License processing times can take anywhere from two months to a year, they are taken on a case-by-case basis).

 

Q: How can someone apply for a specific license?

A: Individuals or entities such as corporations may submit an application for a license to OFAC. Some licenses can Apply for an OFAC License Online. Licenses for which you cannot apply for through the online portal must be submitted as follows: include “a detailed description of the proposed transaction, including the names and addresses of any individuals/companies involved.”   You can learn more about applying for an OFAC Specific License by clicking here. These documents have to be sent by mail or courier to OFAC’s office. OFAC specialized attorneys and sometimes freight forwarders can assist with obtaining an OFAC license for you or your company.

 

Q: What types of cargo are shipped from the US to Iran?

A: Everything from raw commodities such as corn, rice, wheat, lentils to more finished goods like confectionery, chips, beverages, and non-food items such as: fruit and vegetable seeds, dental equipment, medical devices, chemical woodpulp, and more recently electronics among other items.

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To get an insightful and entertaining look into what is shipped from the US to Iran, read this article:  The US has sent nearly $2 million worth of bull sperm to Iran this year.

 

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Persons engaging in transactions pursuant to general or specific licenses must make sure that all conditions of the licenses are strictly observed. This means knowing how to handle the export declaration and which seaports, airports in Iran your cargo is allowed to be shipped according to US law.

Over the past few years, OFAC has issued several general licenses for the export and reexport to Iran of everything from food, medical devices, vitamins, supplements, software, electronics and network equipment.

 

Here is a list of all OFAC General Licenses for Iran:

OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to Iran.   General licenses allow all US  persons to engage in the activity described in the general license without needing to apply for a specific license.

  • Iran General License  – Authorizing the Exportation or Reexportation of Medicine and basic medical supplies to Iran​ (Issued: 10/22/2012)
  • Iran General License  – Authorizing the Exportation or Reexportation of medicine and basic medical supplies to Iran (Updated: 7/25/2013)
  • Iran General License  – Authorizing the Exportation or Reexportation of Food Items
  • Iran  General License​  – Related to Consular Funds Transfers and to the Transportation of Human Remains
  • Iran General License Related to Personal Communication Services    – Exportation of certain services and software over the internet
  • Iran General License (No. 2)  – Authorizing U.S. persons who are employees or contractors of six international organizations to perform transactions for the conduct of the official business of those organizations in or involving Iran
  • Iran General License (No. D)  – General License with Respect to the Exportation and Reexportation of Certain Services, Software, and Hardware Incident to the Exchange of Personal Communications
  • Iran General License (No. E)  – Authorizing Certain Services in Support of Nongovernmental Organizations’ Activities in Iran
  • Iran General License (No. F)  – Authorizing Certain Services in Support of Professional and Amateur Sports Activities and Exchanges Involving the United States and Iran​

If you are seeking to export a commodity not in one of the General Licenses, you can apply for a specific OFAC License by clicking here.

 

Here is a short description of the General License for the Export of Agricultural Commodities to Iran:

“Effective immediately, U.S. persons may export or re-export food to Iran and Sudan without applying for a specific license. OFAC defines the term “food” broadly to cover most items that are consumed by and provide nutrition to human and animals. Product categories specifically enumerated in the two general licenses include: Vitamins and minerals; Food additives and supplements; Bottled drinking water; Seeds used to produce food; and Various bulk agricultural commodities (e.g., durum wheat, various forms of rice, various kinds of oil, such as rapeseed oil). Items not allowed for export:

The new general licenses do not authorize the export or re-export of alcoholic beverages, cigarettes, or gum. Nor do they authorize the export of fertilizer or other non-consumable agricultural commodities. Castor beans and castor been seeds; Raw eggs, fertilized eggs and dried egg albumin; Live animals; Rosary/Jequirity peas; Non-food grade gelatin powder; and Peptones and their derivatives.

 

 

Benefits of selecting an OFAC experienced freight forwarder with experience in Iran OFAC sanctions and regulations is extremely important. There are many areas of export regulations relating to Iran the vast majority of international freight forwarders or NVOCC’s do not want to get involved with nor have the know-how or experience to handle. Additionally, many exporters, including manufacturers, producers, and traders do not wish to get involved in trade with Iran because of what they see as complicated regulations and export compliance. American Export Lines has the experience and know how to handle licensed exports to Iran. Please call us at 310-895-7192 or send a request through Request a Quote.

 

To learn more about what OFAC does and how it operates, please click here.