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Definition of Government-Owned Entity Amended in Iranian Transaction Regulations
March 20, 2012


The Treasury Department’s Office of Foreign Assets Control (OFAC) has issued a final rule amending the Iranian Transaction Regulations (ITR) to redefine the term “entity owned or controlled by the Government of Iran” to substantially conform to the definition in the amended Iranian Financial Sanctions Regulations (IFSR). According to the rule, the term “entity owned or controlled by the Government of Iran” includes any corporation, partnership, association, or other entity in which the Government of Iran owns a 50 percent or greater interest or a controlling interest, and any entity which is otherwise controlled by that government. This final rule takes effect March 20, 2012.

OFAC previously amended the Iranian Financial Sanctions Regulations (31 CFR part 561) and reissued them in their entirety to implement section 1245(d) of the National Defense Authorization Act for FY 2012. In the amended IFSR, OFAC defined the term “entity owned or controlled by the Government of Iran” in a slightly different way from the term’s definition in the Iranian Transaction Regulations. The March 20, 2012, final rule aims to ensure the term is defined consistently across these sanctions programs. OFAC also notes that it intends to issue more thorough amendments to the ITR to implement Executive Order 13599 of February 5, 2012, at a later date.

For further information, please contact a Barnes/Richardson attorney.

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