OFAC’s Basic List of Medical Supplies is getting a lot less basic.

Yesterday, OFAC issued an updated List of Basic Medical Supplies – the supply to Iran of which are generally authorized pursuant to 31 C.F.R. § 560.530(a)(3). The updates involve substantive additions to the List of Basic Medical Supplies in almost all medical areas, including cardiology, obstetrics, ophthalmology, radiology, and surgery. Previously, the added items were available for specific licensing, but now will no longer require prior approval from OFAC before being exported to Iran.

Pursuant to 31 C.F.R. § 560.530(a)(3), the exportation or re-exportation of medicine and medical supplies to the Government of Iran, to any individual or entity in Iran, or to persons in third countries purchasing specifically for resale to the foregoing, and the engagement of related transactions, is generally authorized, provided that certain payment terms are met and all such export or re-exports are shipped within the 12-month period beginning on the date of the signing of the contract for export or re-export. OFAC defines “medical supplies” available for export or re-export as those items included on the List of Basic Medical Supplies that it publishes on its website.   The more expansive the List of Basic Medical Supplies, the more medical supplies available for export or re-export to Iran without requiring specific license authorization from OFAC.

OFAC’s latest update includes several major additions to the List. For instance, additions in the field of radiology include magnetic resonance imaging (MRI) machines, nuclear medicine imaging machines, computer tomography scanners (CT), positron emission tomography (PET), and X-ray machines, such as mammography machines. These changes are major substantive additions beyond what OFAC has previously generally licensed for export or re-export to Iran.

The full list of new additions can be found below.

General Medical Equipment and Supplies

• Bottles (Prescription)
• Capnographs
• Contraceptives (inter uterine devices (IUDs), hormonal therapy methods, barrier methods)- the previous list only accounted for condoms.
• Continuous positive airway pressure (CPAP) systems and all components
• Humidifiers
• Manikins: medical training, CPR
• Medical flowmeters: oxygen & air
• Medical pumps
• Oxygen apparatus, all
• Tents: pediatric, aerosol, and mist
• Ventilator: adult and tubing accessories

Cardiology

• Ablation devices and accessories: radio frequency
• Balloons extractor, retrieval
• Cardiac monitors; implantable or external
• Cardiac pacemaker
• Cardiac programmers
• Cardiopulmonary oxygenation systems, devices, and monitors
• Coagulation machines
• Filters: arterial
• Grafts: peripheral bypass
• Heart positioners: surgical revascularization
• Heart valves: surgical transcatheter (non-surgical)
• Inflation devices: interventional

Dental Equipment and Supplies

• Bone graft matrices
• Dentures, crowns, molds orthodontics, all

Gynecology and Urology

• Extracorporeal lithotripters

Inherited Preventative Care

• Genetic testing products

Laboratory

• Autoclaves (20 liters or smaller only) for medical instrument sterilization and accessories
• Clinical immunoassay analyzers
• Flow cytometry accessories, reagents, and components

Neurology

• Neurostimulators, implantable

Obstetrics and Maternity Care

• Assisted reproductive technology and related equipment
• Incubators/Isolettes
• Infant radiant warmer and parts and accessories
• Neonatal equipment (phototherapy, nasal CPAP, etc. and all components)
• Ventilator: infant/pediatric and tubing accessories

Ophthalmology and Optometry

• Phoropters
• Tonomets
• Vision/Optometry related machines and supplies

Otology and Neurotology

• Hearing aids, accessories, and components

Physical and Occupational Therapy

• Bath cubes, therapy
• Boots, mitts, and liners for therapeutic pain relief
• Orthopedic shoes, boots, etc.

Radiology

• Computer tomography scanners (CT, MDCT)
• Contrasting agents, both injectable or non-injectable
• Magnetic resonance imaging (MRI) machines
• Medical/Dental film
• Nuclear medicine imaging machines
• Parts and accessories for medical imaging devices above that do not contain nuclear or chemical components
• Positron Emission Tomography (PET)
• PET cyclotron machines
• PET radiopharmaceutical tracer machines, including cassettes
• Scintillation Camera/Anger cameras for medical imaging
• Single Photon Emission Computed Tomography (SPECT) machines
• X-ray machines, including mammography machines

Surgery

• Cervical fusion kits
• Cosmetic or reconstructive implants (jaw implants, breast implants, skin grafts)
• Orthopedic plates/screws, fixators, implants, cement
• Surgical case charts
• Surgical imaging machines; including image-guiding surgery products, ear, nose and throat
• Surgical shunts
• Tissue stabilizers, surgical revascularizations