The Iranian Transactions Regulations, 31 CFR part 560 (the "rrR"), administered by US Treasury  Department's Office of Foreign Assets Control, implement a series of Executive orders with respect to Iran, beginning with Executive Order 12957, issued on March 15,1995, Executive Order 12959 (May 6, 1995) and Executive Order 13059 (August 19,1997). The US Department of the Treasury’s Office of Foreign Assets Control (‘‘OFAC’’) have amended the Iranian Transactions Regulations in the Code of Federal Regulations to expand the scope of Appendix A to Part 560 to encompass any person determined by OFAC to be the Government of Iran, as that term is defined in those regulations. The summary of the regulation is:

• Imports: Direct or indirect imports into the United States of goods or services that are of Iranian origin are prohibited. OFAC has issued exemptions for certain transactions, including those related to personal communications, humanitarian donations, informational materials, transactions ordinarily incident to personal travel, and the importation of certain foods (such as dried fruits, nuts and caviar) and certain textiles (carpets and wall hangings). Gifts with a value of less than $100 are also permitted.

• Exports: With very limited exceptions, the regulations prohibit the direct or indirect export or re¬ export to Iran or an Iranian Governmental Person of Iran of all goods, technology and services from the United States, or by U.S. persons wherever located. Also prohibited is (i) the provision of services by a U.S. person to any U.S. person or non-U.S. person if the benefit thereof will be received in Iran (for example, assisting or supporting a firm in a third country in its export operations to Iran) and (ii) the export or re-export of goods, technology or services of any kind to a third country with knowledge or reason to know that such goods, technology or services are intended (a) for transshipment or onward transfer to Iran or (b) for production of non-U.S. services or goods to be provided to Iran. Permitted exports are certain humanitarian donations, certain gifts up to $100 in value, non-financial personal communications and informational materials. Services, including investment banking advice, provided by a non-U.S. branch (but not a foreign-incorporated subsidiary) of a U.S.-incorporated firm are considered to be exported from the United States.

• BIS Export Controls: The export control regulations administered by the BIS, within the U.S. Department of Commerce, restrict the export or re-export without a license to Iran by any person (with or without any ties to the United States) of certain goods, technology or software (note that, unlike OFAC, the BIS does not restrict the export of services). This includes all goods, technology and software that (i) originated in United States or contains more than 10 percent, by value, of U.S components or U.S. content and (ii) is included in the Commerce Control List as a dual-use item. The Iranian Regulations administered by OFAC contain an overlapping prohibition on certain re-exports by non-U.S. persons of U.S.-origin goods or technologies, controlled by the Department of Commerce, unless those goods or technologies have been (i) substantially transformed outside the United States, or (ii) are incorporated into and constitute less than 10 percent of the value of a foreign-made product exported from the third country. OFAC, rather than the BIS, has general licensing authority over exports and re-exports to Iran.

• Petroleum related transactions: U.S. persons may not trade in Iranian oil or in petroleum products reined in Iran, nor may they finance such trading or provide any other services (including financing services), goods or technology that would benefit the Iranian oil industry.

• Transactions involving US affiliates: No U.S. person may approve or facilitate the entry into or performance of transactions or contracts with Iran by a foreign subsidiary of a U.S. firm that the U.S. person is precluded from performing directly. Similarly, no US person may facilitate such transactions by unaffiliated foreign persons. U.S. persons must file a report with OFAC with respect to certain transactions entered into by a foreign affiliate (defined as any entity that is organized or incorporated under non-U.S. law but is owned or controlled by one or more U.S. persons). The transactions that must be reported are purchases, sales and swaps of Iranian-origin crude oil or natural gas, if the foreign affiliate entered into such transactions with an aggregate value of $1 million or more in any calendar quarter.

• Financial dealings: Any new investment, after May 1995, by U.S. persons in Iran or in property owned or controlled by an Iranian Governmental Person is prohibited, whether in the form of funds, assets, loans or any other extension of credit or investment banking services. While U.S. persons may continue to charge fees and accrue interest on existing Iranian loans, a license from OFAC is necessary to reschedule or otherwise extend the maturity of any existing loan. U.S. banks may also cover payments involving Iran that are by order of a third-country bank for payment to another third-country bank, provided they do not directly credit or debit an Iranian account.