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634. Can I, as a non-U.S., non-Iranian person, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period pursuant to contracts entered into prior to May 8, 2018?


Yes, subject to the conditions set out below and in FAQ 631 above, non-U.S., non-Iranian persons may receive payment after the end of the relevant wind-down period for goods or services fully provided or delivered to an Iranian counterparty prior to expiration of the relevant wind-down period (see FAQ 633 above). In particular, the goods or services must have been fully provided or delivered prior to the end of the applicable wind-down period pursuant to a written contract or written agreement entered into prior to May 8, 2018; the relevant activities must have been consistent with U.S. sanctions in effect at the time of delivery or provision, including that the activities did not involve persons on the SDN List at the time of the transaction; and any payments must be consistent with U.S. sanctions, including that payments can not involve U.S. persons or the U.S. financial system, unless the transactions are exempt from regulation or authorized by OFAC (see FAQ 631 and FAQ 636).

Date Released
November 5, 2018