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OFAC Re-Imposes Sanctions on Iran that Were Previously Lifted

On November 5, 2018, the United States fully re-imposed the sanctions on Iran that had been lifted or waived in the past. Sanctions are imposed to adversely affect Iran's infrastructure in the energy & finances, transportation(shipping & ship building). US aims for a maximum financial pressure on Iran.
Such sanctions also have targeted Medical Sectors, diagnostic medical devise and diagnostic laboratory devises.

(OFAC) Office of Foreign Asset Control in the past authorized the exportation or re-exportation of medicine and medical devices to Iran, on or after Nov 5th, 2018 , it imposed sanctions on various medical supplies. The sanction imposed do include restrictions on general medical devices and laboratory diagnostic medical devises. Following is a list of restricted devises:

Oxygen Generators • Pumps with flow rates of more than 1 liter/minute • Diagnostic Medical Imaging Equipment: o Gamma imaging equipment o Tactile Imaging equipment o Thermography equipment Laboratory • Freeze-drying (lypophilizers) and spray-drying equipment • Fermenters, bioreactors, and chemostats • Crossflow (tangential) filtration systems and disposable filter cartridges • Biocontainment chambers and hoods, including isolators, biological safety cabinets, and laminar flow hoods • Aerosol inhalation equipment, including full-body, head-only, nose-only, and mask exposure systems • Decontamination showers • Laboratory glassware made from borosilicate glass, including reaction vessels, storage tanks, heat exchangers, and distillation and absorption columns • Autoclaves larger than 20 liters • Clinical laboratory water baths larger than 10 liters • Laboratory hot plates exceeding 1 square foot of heating surface • Freezers capable of reaching temperatures of -80 degrees Celsius • Laboratory shakers and incubator shakers • Carbon dioxide incubators • Circular dichroism spectrometers • Spectrophotometers not designed for clinical use • Fluorometers • Nuclear Magnetic Resonance Spectrometers • Polymerase Chain Reaction (PCR) machines 2 of 2 • Differential Scanning Calorimeters • Chromatography Equipment • Fluorescence Microscopes • Confocal Microscopes • Cascade Impactors • Dynamic Light Scattering Equipment • Quasielectric Light Scattering Equipment • Full face mask respirators, including Powered Air Purifying Respirators (PAPR) • Decontamination systems using the following chemicals: o Vaporized hydrogen peroxide o Vaporized paraformaldehyde o Vaporized ethylene oxide o Isopropanol (99% purity) • High Efficiency Particulate Air (HEPA) Filtration Systems and HEPA filters • Fourier Transformation Infrared (FTIR) Systems • Balancing machines • Motion simulators • Rate tables.

Specific license is a US government permission to export or reexport, which would happen after details of each specific case is approved. The details of each case does include but is not limited to devices to be exported, parties involved in the export and all specific situations surrounding the transaction. Upon review department of treasury would decide whether to issue permission.

Violating OFAC rules constitute a federal crime. Being involved in a federal crime, whether the violator knows the rules or not would cause conviction , jail time and losing immigration status for an immigrant and all his family members. Consultation with an OFAC lawyer must happen before the transactions that involve national of the countries under sanction. OFAC rules specially in regards to Iranian nationals and government are complex and should not been taken lightly.

It is advisable to seek legal guidance from our office today as we strive to help guide you with your specific case. 

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