Iran Export Controls

License Requirements

A license from BIS is required to export or reexport most items on the Commerce Control List (CCL) to Iran pursuant to Section 746.7 of the EAR. In addition to BIS license requirements, the Department of the Treasury, Office of Foreign Assets Control (OFAC) prohibits unauthorized exports and reexports to Iran of items subject to the Export Administration Regulations pursuant to the Iranian Transactions Sanctions Regulations (ITSR) (31 CFR Part 560).

If OFAC authorized the export or reexport of an item subject to the EAR you are not required to seek separate authorization from BIS to export or reexport that item to Iran. Such OFAC authorization is considered authorization for purposes of the EAR. If an items is subject to the EAR and not subject to OFAC’s ITSR, however, you may need a BIS license to export or reexport that item to Iran.

You will violate the EAR if you export or reexport an items subject to the EAR without a required OFAC authorization, even if the transaction would not have required a license from BIS.

You may need a license from BIS even if you have an authorization from OFAC in certain circumstances. Deemed exports (i.e. transfers of controlled technology and certain software to Iranian nationals in the U.S. or in a third country) will require a BIS license, regardless of OFAC authorization.   Separate BIS authorization may also be required for exports or reexports to prohibited persons – specifically persons on BIS’ entity list -- and exports and reexports for prohibited end uses.  Please review EAR Part 744 to determine if a BIS license is required in addition to OFAC authorization.

Please visit OFAC’s website for information about how to apply to OFAC for a license to export or reexport to Iran. To assist with the OFAC licensing process, BIS maintains classification guidance for medical devices, medicines, and agricultural commodities. Please note that OFAC may require you to obtain a BIS commodity classification to support an application for certain items.

License Exceptions

No license exceptions may be used for an export or reexport to Iran of items subject to the EAR.

Licensing Policy

Applications for licenses for humanitarian reasons and for the safety of civil aviation and the safe operation of U.S.-origin aircraft will be considered on a case-by-case basis. Licenses for other purposes generally will be denied.

Questions

For questions regarding OFAC-administered sanctions against Iran, please visit OFAC’s website or call 800-540-6322. For questions regarding BIS-administered sanctions, you may contact the Foreign Policy Division at 202-482-4252.