What key changes did the December 23, 2016 regulatory amendment to the Iranian Trade and Sanctions Regulations (ITSR) make to the definition of “Iranian-origin goods” or “goods of Iranian origin”?
OFAC's answer
OFAC amended section [560.306](https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=e3c4494665db57ce61ce4c1445726e8e&mc=true&r=PART&n=pt31.3.560#se31.3.560_1306) of the [ITSR](https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=e3c4494665db57ce61ce4c1445726e8e&mc=true&r=PART&n=pt31.3.560) to clarify that the terms “goods of Iranian origin” and “Iranian-origin goods” do not include the following categories of goods, provided that such goods were not grown, produced, manufactured, extracted, or processed in Iran: (i) goods exported or reexported to Iran under an authorization issued pursuant to the ITSR (e.g., a medical device or a personal communications device exported or reexported to Iran pursuant to a general or specific license issued pursuant to the ITSR) and that subsequently have been reexported from and are located outside of Iran, or (ii) goods transported on a vessel or aircraft that passed though Iranian territorial waters or stopped at a port or place in Iran en route to a destination outside of Iran and that have not otherwise come into contact with Iran.