636. Can I receive payment for activities undertaken during the wind-down period if the payment involves a person that has been added to the SDN List, including a person that was previously on the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) but is now designated under another authority?

The United States intends to fully enforce the sanctions that apply to persons that were previously on the E.O. 13599 List but that are now designated under another authority.
U.S. persons and U.S.-owned or -controlled foreign entities generally would require an OFAC authorization to receive any payment involving an SDN, regardless of whether they were previously on the E.O.13599 List. OFAC will evaluate requests for such authorization on a case-by-case basis, including whether payments are for goods or services fully provided or delivered during the wind-down period pursuant to an OFAC wind-down authorization (see FAQ 635).
Non-U.S. persons, including foreign financial institutions, could be subject to sanctions for knowingly engaging in certain significant transactions involving an Iranian person on the SDN List – other than a non-designated Iranian financial institution – or a person designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, including a person that was previously on the E.O. 13599 List but is now designated under another authority. Such persons will have a notation of “Additional Sanctions Information – Subject to Secondary Sanctions” in their SDN List entry in addition to the tag for the other sanctions program(s) (e.g., the “[SDGT]” tag, the “[IRAN-HR]” tag, or the “[NPWMD]” tag for persons designated under E.O. 13224, E.O. 13553, or E.O. 13382).
Non-U.S., non-Iranian persons seeking to receive payment for activities undertaken during the wind-down period that involves a person added to the SDN List should seek guidance from OFAC or the State Department, as appropriate (see FAQ 634).