Sometimes you feel like a nut…

August 15, 2010
Two Iranian nuts

Ahmadinejad & Mr. Pistachio (a.k.a. Ayatollah Rafsanjani)

OFAC issued guidance last week related to the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, which was signed into law by Pres. Obama this summer.  “International Trade Law News” tells us what this means for Americans:  no more Persian rugs, no pistachio nuts:

OFAC’s Iranian Transactions Regulations currently contain a general license authorizing the importation into the U.S. of foodstuffs from Iran that are classified under chapters 2-23 of the Harmonized Tariff Schedule of the United States (HTS) (such as pistachios and non-beluga caviar (which is prohibited by other aspects of law). In addition, the importation of carpets and other textile floor coverings of Iranian origin that are classified under chapter 57 or heading 9706.00.0060 of the HTS are also authorized.

However, due to the additional Iran sanctions recently passed by Congress, OFAC will soon issued [sic] a regulation amending the Iranian Transaction Regulations to eliminate the general license and such imports will be no longer permitted starting on September 29, 2010. OFAC has also indicated that any authorized Iranian products must be imported by September 28, 2010 and it will not issue any specific licenses authorizing any imports after that date. As a result, importers must move quickly to ensure that any pending orders are entered for consumption by their customs brokers by September 28, 2010.

Attempts to import Iranian origin foodstuffs and carpets after September 28th can lead to significant civil and criminal penalties. For example, civil penalties of up to $250,000 or twice the amount of the transaction that is the basis of the violation can be imposed administratively. Criminal penalties of up to $1,000,000 in fines and imprisonment for up to 20 years can be imposed for willful violations of the Iranian Transaction Regulations.

The move could seem punitive considering that thousands of Iranian pistachio farmers rely on exports, which have already been hurt by crop shortfalls and the “Dutch Disease”.  Food sanctions would also seem to undercut the administration’s argument that they are pursuing “smart” sanctions that only target specific individuals, businesses, and technologies tied to Iran’s nuclear program.

On the other hand, the days of the small, family pistachio farm are numbered.  The sector has long since been taken over by multi-millionaire mullahs & bonyad conglomerates.  The nuttiest politicians of Iran like Ayatollah Rafsanjani have acquired a fortune by exploiting the pistachio industry.

In any case, and Levi Johnston’s pistachio advice notwithstanding, I think I’ll stick to eating good old-fashioned Georgia peanuts for a while.


  1. Following the Embassy takeover in 1979 California started planting pistachio groves. If I remember correctly, it took almost 7 years to yield crops. Feel comfortable in purchasing nuts from the State of Nuts, USA.

    Come to think of it, I don’t think I’ve seen a bag of imported pistachios from Iran since, unless you count mullahs, which seems perfectly reasonable.

    • That is somewhat reassuring to hear, Sadie.

      Iran has a lot of back channels/front companies they use to engage in business in America, so I hope folks in the the nut industry and in import-export businesses are making sure they know who they’re really working with…

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