Frequently Asked Questions

810. On December 11, 2019, the State Department announced that it would designate the Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping Limited (“E-Sail”) under Executive Order (E.O.) 13382, effective June 8, 2020. IRISL and E-Sail are already listed on the SDN List. What will be the impact of the State Department’s designation of these entities under E.O. 13382?

810 … On November 5, 2018, OFAC identified IRISL and E-Sail on the SDN List with the [IRAN] tag to indicate that they are entities meeting the definition of the Government of Iran whose property and interests in property are blocked pursuant to E.O. 13599. Following their designation by the State… 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

318. Does the GL for medical devices authorize the exportation or reexportation of all medical devices?

318 … No. The GL for medical devices appearing at section 560.530 (a)(3)(i) of the Iranian Transactions and Sanctions Regulations ( ITSR ) authorizes covered persons, as defined in section 560.530(e)(4), to export or reexport to Iran medical devices as defined in section 560.530(e)(3) of the ITSR,… Read more

319. Does the GL for medical devices authorize the exportation or reexportation of these items to all entities in Iran?

319 … No. While the GL under section 560.530 (a)(3)(i) of the Iranian Transactions and Sanctions Regulations ( ITSR ) authorizes exports or reexports of certain medical devices to most entities in Iran, it does not authorize exports or reexports to military, intelligence, or law enforcement… Read more

361. What items and persons are excluded from the agricultural commodities general license in the Iranian Transactions and Sanctions Regulations (ITSR)?

361 … The specified items excluded from the scope of the agricultural commodities general license are: castor beans, castor bean seeds, certified pathogen-free eggs (unfertilized or fertilized), dried egg albumin, live animals (excluding live cattle, shrimp, and shrimp eggs), embryos (excluding… Read more

362. Is the exportation or reexportation of non-U.S.-origin agricultural commodities, medicine, or medical devices by a U.S. person to Iran authorized?

362 … Yes. The definitions of the terms “agricultural commodities,” “medicine,” and “medical device” used in the relevant general licenses in the ITSR include, in the case of items subject to Commerce's Export Administration Regulations (EAR), items that are designated as EAR99 and, in the case of… Read more

363. Is the exportation or reexportation by non-U.S. persons of agricultural commodities, medicine, or medical devices that are subject to the Export Administration Regulations (EAR) to Iran authorized?

363 … Yes. A non-U.S. person may export or reexport agricultural commodities, medicine, or medical devices to Iran under the relevant general licenses in the ITSR , provided that the items are subject to Commerce's Export Administration Regulations (EAR); and all conditions of the relevant general… Read more

364. Who can apply for a specific license if an export or reexport to Iran is not authorized by general license?

364 … If an export or reexport is not authorized by general license, any U.S. person, or non-U.S. person exporting items subject to Commerce's Export Administration Regulations (EAR); and designated as EAR99, wherever located, or U.S.-owned or -controlled foreign entity may apply for a specific… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence