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301. How will the determination be made as to whether materials are used in a manner that would make them subject to sanctions under section 1245 of IFCA?


A FFI, prior to conducting or facilitating a significant financial transaction for the sale, supply, or transfer to or from Iran of the materials listed in 1245(d) – as described in part in Q&A 298– will need to undertake due diligence to ensure that the transaction does not involve the materials being sold, supplied, or transferred, directly or indirectly, to or from Iran for sanctionable uses under section 1245. Pursuant to delegated authority, the Secretary of State issues periodic reports pursuant to section 1245(e) of IFCA, which contains determinations on which materials identified in section 1245(d) are used by Iran as a medium for swap or barter, are listed as assets on the national balance sheet of Iran, or are used in connection with the nuclear, military, or ballistic missile programs of Iran.

Date Released
August 6, 2018