Background

The Bureau of Industry and Security has issued a final rule that, effective July 23, expands controls on shipments of certain foreign-produced items located in or destined to Iran. BIS states that it has made these changes in an effort to further impede Iran’s ability to procure technology and components critical for military systems, including advanced drones that pose threats to U.S. forces and allies.

The rule expands the scope of the Export Administration Regulations’ Iran foreign direct product rule by requiring a license for the export, reexport, and transfer (in-country) of additional foreign-produced items located in or destined to Iran. It also adds a new end-user scope that targets transactions involving such items in which the government of Iran is known to be a party; e.g., as a purchaser, intermediate consignee, ultimate consignee, or end-user.

Shipments of items removed from license exception eligibility or eligibility for export, reexport or transfer (in-country) without a license as a result of this rule that were on dock for loading, on lighter, laden aboard an exporting carrier, or en route aboard a carrier to a port of export, on July 26 pursuant to actual orders for export, reexport, or transfer to a foreign destination may proceed to that destination under the previous license exception eligibility or without a license so long as they have been exported, reexported, or transferred before Aug. 26. Any such items not actually exported, reexported, or transferred before midnight on Aug. 26 will require a license in accordance with this rule.

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