Frequently Asked Questions

607 … After the 180-day wind-down period ends on November 4, 2018, the following sanctions come into effect, including under provisions of E.O. 13846 and relevant statutory authorities: i. Sanctions on Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic… Read more

608 … Section 6 of E.O. 13846 reimposes the sanctions previously contained in section 1 of E.O. 13645 with respect to transactions involving the Iranian rial. FFIs risk correspondent and payable-through account sanctions and blocking sanctions if they, on or after August 7, 2018, (i) knowingly… Read more

263 … In order for the National Defense Authorization Act's ( NDAA ) significant reduction exception to apply on or after February 6, 2013, the person receiving payment (e.g., the manufacturer or service provider) for goods or services being exported to Iran must be – (i) a citizen, national, or… Read more

264 … No. If funds from the RECIPIENT ACCOUNT or the SPECIAL PURPOSE ACCOUNT are remitted, directly or indirectly, to Iran, or paid to any person that is the GOI , the FFI would be exposed to sanctions. … Can funds be remitted to Iran or the Government of Iran (GOI) without exposure to …

265 … The National Defense Authorization Act of Fiscal Year 2012 (NDAA) generally exempts from sanctions sales made under the Humanitarian Exception (i.e., the sale of agricultural commodities, food, medicine, or medical devices from third countries to Iran). Funds deposited in the RECIPIENT… Read more

314 … Yes. So long as the transaction does not involve a designated individual or entity, banks on the Part 561 List located on OFAC’s website, or otherwise proscribed conduct, such transactions are not sanctionable under U.S. law. Furthermore, there is no requirement under U.S. law that… Read more

177 … Section 1245 targets any significant transactions “with” the CBI; a transaction involving the CBI in an intermediary role would likely be viewed as a transaction “with” the CBI. … If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise… Read more

178 … If a transfer involves a financial institution it would likely be considered a financial transaction . … Are barter trades involving the Central Bank of Iran (CBI) considered “financial transactions” under Section …

338 … Qualifying services under 31 CFR § 560.540(a)(1) are those that are “incident to the exchange of communications over the internet,” as well as cloud-based services in support of such services or of any other transaction authorized or exempt under the ITSR.  Qualifying software under 31 CFR §… Read more

179 … This will be a case-by-case determination and will require specifics on what “passive holding” entails. As a general matter, we would likely not view the holding of reserves as sanctionable in the following circumstances: the accounts are frozen or restricted, under which the CBI would be… Read more