◢ In the years when Iran was under broad international sanctions, the country saw shortages in key foodstuffs and life-saving medicines. Despite attestations to the contrary, international sanctions hurt the Iranian people in cruel ways. As Iranians prepare for the return of U.S. sanctions, concerning ambiguity in OFAC’s new sanctions guidance may undermine the longstanding exemptions for humanitarian trade and the carve-outs for the Iranian banks which facilitate these sales.