On July 25, 2013, the Office of Foreign Asset Control (“OFAC”) announced the significant expansion of its List of Basic Medical Supplies (“LBMS”). Simultaneously, OFAC issued clarifying Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran. These actions are intended by OFAC to demonstrate the United States’ commitment to safeguarding humanitarian aid to and within Iran.
The Expanded General License -
As part of its October 2012 reissuance of the Iranian Transactions and Sanctions Regulations (“ITSR”), OFAC added a new General License to authorize the exportation or re-exportation of certain medical supplies to Iran. Previously, the export of such items required a license under the Trade Sanctions Reform Act (“TSRA”). Items that previously required a specific TSRA license, but which can now be exported under the General License, include basic medical supplies (items identified on the LBMS), as well as EAR99 medicines and medical devices, defined respectively as “drugs” and “devices” in section 201 of the Federal Food, Drug, and Cosmetic Act.
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