BIS adds a number of companies to the Entity List, including Iran Air

As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List.

Summary -

Companies that use Iran Air as transport, particularly companies engaging in the sale of food, medicine, and medical devices pursuant to the general license (31 C.F.R. § 560.530, or the ag/med general license (GL)) issued by the Office of Foreign Assets Control (OFAC), should review their business arrangements for such sales and assess any potential impact of this designation. While use of Iran Air to transport authorized items is not per se prohibited, involvement of Iran Air is a red flag that would need to be addressed as described below. BIS' action comes shortly after OFAC provided guidance regarding the Central Bank of Iran's involvement in sales authorized under the ag/med GL.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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