No, non-U.S. persons are generally not exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846.
However, please note that non-U.S. persons should ensure that the provision of goods or services to, or other transactions with such non-Iranian persons do not involve: (1) prohibited transactions by U.S. persons (including U.S. financial institutions) or U.S.-owned or -controlled foreign entities, unless the transaction is exempt from regulation, or authorized by OFAC; (2) the knowing provision of significant support to an Iranian person on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List); or (3) the knowing facilitation of a significant transaction for a person on the SDN List that has been designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, including designated Iranian financial institutions or the Islamic Revolutionary Guard Corps (IRGC), or other activity for which sanctions have been imposed with respect to Iran (e.g., knowingly engaging in a significant transaction for the purchase of petroleum from Iran).
For information about persons sanctioned by State Department pursuant to Section 3 of E.O. 13846, please see the relevant State press statement or Federal Register Notice.