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Clarification and Updated Information Regarding Iran Air Designation on the SDN List

07/01/11 Source: Pars Equality Center (Pars)

Dear fellow Iranian Americans,

On June 23, 2011, new sanctions were issued by the U.S. Department of Treasury, Office of Foreign Asset Control (OFAC) which now list Iran Air and Iran Air Tours on the “Specially Designated Nationals Blocked Persons List” (SDN List) under the Non-proliferation Weapons of Mass Destruction (NPWMD) sanctions program. This means that transactions of U.S. persons with Iran Air and Iran Air Tours must comply with both the Iran Transaction Regulations of the Code of Federal Regulations (C.F.R.) Title 31 Part 560 and the Weapons of Mass Destruction Proliferators Program 31 C.F.R. Part 544.

Both sets of regulations contain an exception for travel related transactions. Part 560.210 (d) of the Iranian Transactions Regulations and Part 544.206 (c) of the Weapons of Mass Destruction Proliferators Program state,

The prohibitions contained in this part do not apply to any transactions ordinarily incident to travel to or from any country, including importation of accompanied baggage for personal use, maintenance within any country including payment of living expenses and acquisition of goods or services for personal use, and arrangement or facilitation of such travel including nonscheduled air, sea, or land voyages.

Part 560.210(d) of the Iran Transactions Regulations further clarifies:

This exemption extends to transactions with Iranian carriers and those involving group tours and payments in Iran made for transactions directly incident to travel.

These regulations and their exceptions apply to all U.S. persons and entities (companies, non-profit groups, government agencies, etc.) wherever located in the world. Both sets of regulations define U.S. person to mean any United States citizen, permanent resident alien, or any person in the United States. This includes any person in the United States, including U.S. visa holders if present in the United States.

What This Means to the Iranian American Community:

We understand that these sanctions laws can be complicated and confusing. Please note, this media alert should not be regarded as legal advice; it is for informational and educational purposes only. Should you have specific questions, please do not hesitate to contact Pars Equality Center. As the lawyers for the Iranian American community, we are proud to serve you. Our website is and we can be reached at (415) 274-8000 or at

About Pars Equality Center

Pars Equality Center (Pars)
is committed to engaging the Iranian-American community in reigniting the promise of the United States.  Pars Equality Center is the first-and currently only-organization of its kind dedicated solely to the rights and dignities of Iranian peoples in the United States. With a non-partisan, collaborative approach, Pars raises public awareness and amplifies Iranian-American perspectives in law, policy, and the media. Visit for more information.

Related Information:

Iran Sanctions- (U.S. Department of the Treasury
Iran Sanctions (U.S. Department of the Treasury)

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