Frequently Asked Questions

161. If all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions are blocked, can I conduct transactions involving the Government of Iran that have been previously authorized by OFAC?

Generally yes. Under new General License A, almost all transactions that are authorized under existing general licenses issued pursuant to the Iranian Transactions Regulations (ITR) or under existing OFAC specific licenses will continue to be authorized under the authority of E.O. 13599. However,… Read more

162. Are U.S. persons still required to comply with the Iranian Transactions Regulations (ITR)?

Yes. E.O. 13599 builds upon the prohibitions of the ITR, and the prohibitions of the ITR remain in effect. …

487. Are goods that are unloaded from a ship in an Iranian port, put on a truck, and driven out of the boundaries of the port or place of unloading considered to be Iranian-origin goods?

Yes. These goods have otherwise come in contact with Iran and thus do not fall within the carve-out to the definition of Iranian-origin goods or goods of Iranian-origin at section 560.306 (b)(2) of the ITSR . However, if these goods are being exported or reexported to Iran under an authorization… Read more

163. What are the differences and similarities between E.O. 13599 and the Iranian Transactions Regulations (ITR)?

The ITR prohibit prohibit virtually all direct or indirect transactions involving Iran or the Government of Iran by U.S. persons or with a nexus to the United States, unless otherwise authorized by OFAC or exempted by statute, but they do not contain blocking provisions. E.O. 13599 requires U.S.… Read more

164. The Iranian Transactions Regulations (ITR) authorize U.S. depository institutions and U.S. registered brokers or dealers in securities to process transfers of funds to or from Iran if the transfer is a non-commercial, personal remittance. Are U.S. depository institutions and U.S. registered brokers or dealers in securities still authorized to process such payments to or from a Government of Iran-owned bank that is not otherwise designated pursuant to another part of 31 C.F.R. Chapter V?

General License B under E.O. 13599 authorizes U.S. depository institutions and U.S. registered brokers or dealers in securities to process noncommercial, personal remittances to or from Iran provided that the payment is not made by, to, or through a financial institution designated by OFAC under… Read more

165. To what extent are U.S. persons expected to conduct enhanced due diligence to determine if transactions contain a Government of Iran interest?

E.O. 13599 requires U.S. persons to block all property and interests in property of the Government of Iran, unless otherwise exempt or authorized by OFAC. Please contact the OFAC Compliance Hotline , for guidance regarding entities that you suspect are owned or controlled by the Government of Iran… Read more

488. Are goods that are unloaded from a ship in an Iranian port, moved within the boundaries of the port, and loaded onto a second ship en route to a destination outside of Iran, without ever leaving the port considered to be Iranian-origin goods?

No, provided that they have not otherwise come in contact with Iran. …

166. OFAC’s SDN List contains a list of entities identified by OFAC as being the Government of Iran. Should U.S. persons now block the property and interests in property of those entities?

Yes, U.S. persons should now block the property and interests in property of the Government of Iran entities appearing on the SDN List , unless OFAC has authorized the underlying transaction or the transaction is …

167. OFAC has granted my company a license under the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”) and the Iranian Transactions Regulations (ITR). Can I continue to conduct the licensed transaction?

Under General License A issued pursuant to E.O. 13599 , transactions authorized under existing specific licenses issued pursuant to TSRA and the ITR are authorized under E.O. 13599 until the specific license expires, per the terms of the …

168. OFAC has issued me a (non-TSRA) specific license related to Iran, or the Government of Iran. Can I continue to conduct the licensed transactions?

Under General License A issued pursuant to E.O. 13599 , transactions authorized by (non-TSRA) specific licenses issued prior to the issuance of E.O. 13599 and issued pursuant to any part of 31 C.F.R. chapter V are also authorized under E.O. 13599. As set forth in General License A, in most cases… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence