Frequently Asked Questions

644 … Yes. Under section 560.215 of the ITSR, U.S.-owned or -controlled foreign entities are prohibited from knowingly engaging in any transaction, directly or indirectly, with the Government of Iran or any person subject to the jurisdiction of the Government of Iran that would be prohibited by the… Read more

645 … Following the re-imposition of U.S. sanctions on November 5, 2018, sanctions that had previously been lifted or waived as part of U.S. commitments under the Joint Comprehensive Plan of Action (JCPOA) will come back into effect in their entirety, including sanctions on the provision of… Read more

622 … To the extent a transaction is exempt from the prohibitions of the ITSR , E.O. 13599 , or section 1 or 15 of E.O. 13846 , or is authorized by a general license issued pursuant to these authorities if engaged in by a U.S. person, it would not be prohibited for a U.S.-owned or -controlled… Read more

666 … E.O. 13871 authorizes sanctions with respect to the iron, steel, aluminum, and copper sectors of Iran. Section 1 of E.O. 13871 authorizes blocking sanctions on any person determined by the Secretary of the Treasury, in consultation with the Secretary of State: (i) to be operating in the iron… Read more

667 … E.O. 13871 became effective upon signing. … When does E.O. 13871 become effective? …

668 … Persons engaged in transactions that could be sanctioned under E.O. 13871 had a 90-day period after the issuance of E.O. 13871 to wind down those transactions without exposure to sanctions under E.O. 13871. Those persons were advised to take the necessary steps to wind down transactions by… Read more

669 … Yes. E.O. 13871 expands upon existing sanctions under section 1245 of IFCA on the sale, supply, or transfer, directly or indirectly, to or from Iran of certain materials, including raw and semi-finished metals such as aluminum and steel, as described in subsections 1245(a)(l)(B) or (C) of… Read more

670 … Yes. The sanctions authorized under E.O. 13871 do not apply to transactions for the conduct of the official business of the United States Government or the United Nations (including its specialized agencies, programmes, funds, and related organizations) by employees, grantees, or contractors… Read more

671 … The interpretation of “significant transaction or transactions; significant financial services; significant financial transaction,” as described in the correspondent account sanctions in the IFSR, provides that the Department of the Treasury may consider the totality of the facts and… Read more

683 … The interpretation of “significant transaction or transactions,” as described in the ISHR provides that the Department of the Treasury may consider the totality of the facts and circumstances and sets forth a list of broad factors that can play a role in the determination whether transactions… Read more