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New End-User Restrictions on SDNs: OFAC Designates German Entities; BIS Revises Part 744

  • BIS has revised part 744 of the EAR to add and expand end-user controls on persons designated by OFAC under 14 sanctions programs
  • The final rule introduces licensing restrictions on export, reexport, and transfer involving designated persons
  • § 744.8 applies to transactions not regulated by OFAC, with a prohibition on using license exceptions
  • BIS authorization is required unless OFAC issues a general or specific license for transactions involving blocked persons
  • OFAC designated Maziar Karimi, a dual Iranian-German national, for procuring items for Iran’s IRGC ASF
  • Karimi’s companies trade industrial machinery, technical products, and spare parts
  • Transactions involving SDN-designated persons could result in a violation of the EAR

Source: awb-international.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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