Does General License (GL) O authorize all wind-down transactions for any vessel that was blocked on March 2, 2023? What if the vessel contains Iranian-origin merchandise?
OFAC's answer
[Iran GL O](https://ofac.treasury.gov/media/931456/download?inline)authorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 of [Executive Order 13846](https://ofac.treasury.gov/media/30181/download?inline) involving any vessel blocked as part of the March 2, 2023 designation (“blocked vessels”), subject to certain conditions. This includes, among other activities, the unloading of any non-Iranian merchandise loaded on the blocked vessel as of March 2, 2023, provided there is no other sanctions nexus. U.S. persons are separately prohibited, pursuant to the [Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-560?toc=1), from engaging in most Iran-related transactions. Accordingly, for blocked vessels containing Iranian-origin merchandise or involving persons ordinarily resident in Iran, Iran GL O provides a separate, more limited authorization under the ITSR. This narrower authorization under the ITSR allows only transactions ordinarily incident and necessary to certain limited safety and environmental situations: the safe docking and anchoring of any of the blocked vessels in port; the preservation of the health and safety of the crew; or emergency repairs or environmental mitigation or protection activities. The offloading of Iranian-origin petroleum, petroleum products, or petrochemical products, regardless of the situation, is not authorized pursuant to Iran GL O and requires a specific license from OFAC. U.S. financial institutions may also process transactions conducted by non-U.S. persons if such transactions would be authorized for U.S. persons pursuant to Iran GL O. Iran GL O is in effect until 12:01 eastern daylight time, June 30, 2023. Persons unable to complete authorized transactions involving the blocked vessels specified in Iran GL O before its expiration are encouraged to seek guidance from OFAC in advance of that date. As with all OFAC GLs, Iran GL O only authorizes against the authorities identified in the GL and contains certain conditions. Please see [Iran GL O](https://ofac.treasury.gov/media/931456/download?inline) for further details.