• March 28, 2024

The Only Comprehensive Resource on U.S. Economic Sanctions

No More Rugs, Pistachios, or Caviar; All Iranian Origin Imports Banned

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After waiting anxiously for the past six (6) weeks, OFAC has finally issued guidance on how the import ban found in the Comprehensive Iran Sanctions, Accountability, Divestment Act of 2010 (“CISADA”) would be reflected in the Iranian Transactions Regulations (“ITR”). The main question a lot of people were asking was whether the general license authorizing the importation of certain Iranian-origin goods (i.e., rugs, pistachios, caviar) would remain intact.

The good news is that OFAC has provided some guidance on this issue. The bad news is that the mandates of the CISADA will be strictly reflected in the ITR. As such, beginning September 29, 2010, all imports of Iranian origin goods are banned. This guidance clarifies a point upon which I and others have been speculating upon ever since the CISADA was passed: how strict would OFAC’s interpretation of the new legislation be? It seems that there might be room within International Emergency Economic Powers Act (“IEEPA”) and the President’s powers for a something other than a strict interpretation of the mandates of the CISADA; and surely, many small business owners selling certain types of Iranian goods were hoping for just that. Unfortunately, this isn’t the case and obtaining Iranian origin goods in the United States legally after September 29, 2010, is going to become nearly impossible.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC litigation. If you have any questions please contact him at 202-280-6370 at 202-351-6161 or ferrari@ferrari-legal.com.

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Erich Ferrari

As the Founder and Principal of Ferrari & Associates, P.C., Mr. Ferrari represents U.S. and foreign corporations, financial institutions, exporters, insurers, as well as private individuals in trade compliance, regulatory licensing matters, and federal investigations and prosecutions. He frequently represents clients before the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United States Department of Commerce’s Bureau of Industry and Security (BIS), and in federal courts around the country. With over 12 years of experience in national security law, exports control, and U.S. economic sanctions, he counsels across industry sectors representing parties in a wide range of matters from ensuring compliance to defending against federal prosecutions and pursuing federal appeals.

2 Comments

  • Does the ban only cover imports by businesses, or does it also apply to individuals who travel there and would like to bring caviar or pistachios for example, back from Iran?

  • Very helpful and informative Website, it would be good to have a Search section

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