US – State provides certain temporary sanctions relief

On August 28, 2014, the Department of State published in the Federal Register a notice [Public Notice 8855] renewing temporary waivers of certain sanctions to allow for a discrete range of transactions related to the provision of satellite connectivity services to the Islamic Republic of Iran Broadcasting (IRIB). The U.S. Government (USG) is renewing these waivers based on Iran’s commitment to ensure that harmful uplink satellite interference does not emanate from its territory, and verification by the USG that harmful uplink satellite interference is not currently emanating from the territory of Iran. The following are waived:

1. Section 1244(c)(1) of the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) 1 to the extent required for:

a. Transactions involving the provision of ground connectivity services using earth stations and fiber optic connections outside of Iran and the provision and management of satellite capacity for sale or resale to the IRIB, where such ground connectivity services and satellite capacity are to be used for the provision to Iran of public international telecommunications services, and

b. transactions involving the provision of the following related administrative services to, or for the benefit of, the IRIB, to the extent such services are necessary to establish and maintain ground and satellite connectivity with IRIB: Standard operational support, including coordinating with in-country personnel on matters such as configuring ground and earth station equipment to access space segment capacity; marketing services; billing services; and legal services, and excluding any transactions involving persons other than the IRIB on the SDN List.

2. Section 1246(a) of IFCA 2 to the extent required for the provision of underwriting services or insurance or reinsurance for:

a. Transactions involving the provision of ground connectivity services using earth stations and fiber optic connections outside of Iran and the provision and management of satellite capacity for sale or resale to the IRIB, where such ground connectivity services and satellite capacity are to be used for the provision to Iran of public international telecommunications services, and excluding any transactions involving persons other than the IRIB on the SDN List; and

b. transactions involving the provision of the following related administrative services to, or for the benefit of, Iran, to the extent such services are necessary to establish and maintain ground and satellite connectivity with IRIB: Standard operational support, including coordinating with in-country personnel on matters such as configuring ground and earth station equipment to access space segment capacity; marketing services; billing services; and legal services, and excluding any transactions involving persons other than the IRIB on the SDN List.

3. Section 1247(a) of IFCA 3 to the extent required for transactions by foreign financial institutions on behalf of IRIB involving:

a. The provision of ground connectivity services using earth stations and fiber optic connections outside of Iran and the provision and management of satellite capacity for sale or resale to the IRIB, where such ground connectivity services and satellite capacity are to be used for the provision to Iran of public international telecommunications services, and for associated services, and

b. transactions involving the provision of the following related administrative services to, or for the benefit of, Iran, to the extent such services are necessary to establish and maintain ground and satellite connectivity with IRIB: Standard operational support, including coordinating with in-country personnel on matters such as configuring ground and earth station equipment to access space segment capacity; marketing services; billing services; and legal services.