Now that’s a sentence! OFAC issues FAQ on Iranian overflights and emergency landings

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Question Relating to the Payments or the Facilitation of Payments to Iranian civil Aviation Authorities for Overflights of Iran or Emergency Landing in Iran

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417. Are payments or the facilitation of payments to Iranian civil aviation authorities for overflights of Iran or emergency landing in Iran by aircraft that are owned by a non-U.S. person and registered outside the United States sanctionable under U.S. law?

Provided that the relevant transactions do not involve persons on the Specially Designated Nationals and Blocked Persons List (SDN List) other than any political subdivision, agency, or instrumentality of the Government of Iran listed solely pursuant to Executive Order 13599 or any Iranian depository institution listed solely pursuant to Executive Order 13599, payments of charges for services rendered by the Government of Iran in connection with the overflight of Iran or emergency landing in Iran of aircraft owned by a non-U.S. person and registered outside the United States are not subject to sanctions under U.S. law. Please note that the involvement of other persons on the SDN List, including Iranian financial institutions designated pursuant to Executive Order 13224 or Executive Order 13382, would create sanctions exposure for participants to such transactions. [09-23-2014]