Frequently Asked Questions

832. What are significant goods or services used in connection with a sector of the Iranian economy specified in Executive Order (E.O.) 13902?

832 … Persons who have knowingly engaged in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with the construction, mining, manufacturing, textiles, and financial sectors of the Iranian economy as described in FAQ 831… Read more

833. How will the terms “knowingly” and “significant” be interpreted for purposes of Executive Order (E.O.) 13902?

833 … As a general matter, the Department of the Treasury intends to rely, where applicable, on definitions of terms previously included in Treasury regulations. For purposes of E.O. 13902 , OFAC will rely on the definition of " knowingly " included in the Iranian Financial Sanctions Regulations at… Read more

1087. Does the general license at 31 CFR § 560.540 authorize the exportation of fee-based or no-cost cloud-based services and software to Iran that are used to support communications tools authorized by 31 CFR § 560.540?

1087 … Yes. Section 560.540(a)(1) of the ITSR authorizes the exportation to Iran of fee-based or no-cost cloud-based services incident to the exchange of communications over the internet. In addition, 31 CFR § 560.540(a)(2) authorizes the exportation to Iran of cloud-based software that is… Read more

1088. What are OFAC’s due diligence expectations for cloud-based service or software providers whose services and software support communication tools are authorized by 31 CFR § 560.540?

1088 … A cloud-based service or software provider whose non-Iranian customers provide services or software to persons in Iran via the cloud may rely upon the authorization in 31 CFR § 560.540 to provide access to Iran, provided that such provider conducts due diligence based on information… Read more

1089. Can persons seeking to export software, services, or hardware to Iran in support of internet freedom apply for a specific license from OFAC if the export is not authorized by 31 CFR § 560.540?

1089 … Yes, persons seeking to export software, services, or hardware to Iran or conduct other activities in support of internet freedom in Iran that are not exempt transactions or authorized by the general license in 31 CFR § 560.540 or other authorizations are encouraged to submit a specific… Read more

842. What does General License L (GL L) authorize with respect to the financial sector of Iran and Iranian financial institutions (Iranian FIs) now sanctioned pursuant to Executive Order (E.O.) 13902?

842 … GL L authorizes under E.O. 13902 all transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 that are authorized, exempt, or otherwise not prohibited under the Iranian Transactions and Sanctions Regulations (ITSR). E.O. 13902, which was issued on January 10, 2020, is… Read more

843. I’m a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) to conduct humanitarian-related or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. 13902. Is any further authorization needed to conduct such transactions following these actions?

843 … No. General License (GL) L extends authorizations provided through specific and general licenses issued under the ITSR to apply to transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 . Further authorization from OFAC beyond GL L is not required under E.O. 13902… Read more

844. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions, or other activities that would be authorized under the Iranian Transactions and Sanctions Regulations and General License (GL) L if engaged in by a U.S. person, involving Iranian financial institutions (Iranian FIs) sanctioned pursuant to E.O. 13902?

844 … No. Non-U.S. persons generally do not risk exposure to U.S. secondary sanctions for engaging in the sale of agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in E.O. 13902 and other applicable sanctions authorities… Read more

845. Will there be a wind-down period for non-U.S. persons engaged in previously non-sanctionable activity involving the Iranian financial sector or Iranian financial institutions (FIs) that are now sanctioned pursuant to E.O. 13902?

845 … Yes. Non-U.S. persons engaged in transactions and activities involving the Iranian financial sector or any Iranian FI sanctioned pursuant to E.O. 13902 that were not previously sanctionable will have 45 days to conclude these activities without risking exposure to sanctions. The 45-day wind… Read more

846. How do the sanctions imposed on the Iranian financial sector and Iranian financial institutions (FIs) pursuant to Executive Order (E.O.) 13902 affect waivers issued by the Department of State and exceptions set forth in the Iranian Freedom and Counter-proliferation Act of 2012 (IFCA)?

846 … Waivers issued by the Department of State (State) and exceptions set forth in IFCA remain valid and activities conducted under them involving Iranian FIs are not sanctionable during the wind-down period described in FAQ 845 . Persons engaged in transactions or activities involving the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence