OFAC FAQ #617 · Iran Sanctions
E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or NICO subsidiary? Are transactions with those entities also sanctionable under this E.O.?
OFAC's answer
Yes. As in E.O. 13622, [E.O. 13846](https://ofac.treasury.gov/media/30181/download?inline) defines NIOC and NICO to include any entity owned or controlled by, or operating for or on behalf of, NIOC and NICO.