Frequently Asked Questions

293. What will the “energy, shipping, and shipbuilding sectors of Iran” mean for the purposes of IFCA?

293 … We anticipate that regulations to be promulgated will define “energy sector of Iran” to include activities involving the exploration, extraction, production, refinement, or liquefaction of petroleum, natural gas, or petroleum products in Iran. (See also discussion of activities involving… Read more

853. Can U.S. academic institutions provide online learning services to Iranian students located outside the United States? Can U.S. technology companies provide software and services to assist Iranian students in accessing online coursework?

853 … General licenses issued under the Iranian Transactions and Sanctions Regulations (ITSR) authorize certain U.S. academic institutions and other U.S. persons to provide certain services and software to Iranian students. These general licenses include: General License G (GL G) authorizes… Read more

855. How will transactions related to official activities of international organizations be treated for purposes of secondary sanctions to the extent that the Iranian financial sector or Iranian financial institutions sanctioned under Executive Order (E.O.) 13902 are involved?

855 … Pursuant to Section 12 of E.O. 13902 , the prohibitions of E.O. 13902 do not apply to transactions for the conduct of the official business of the United Nations (including its specialized agencies, programmes, funds, and related organizations) by employees, grantees, or contractors thereof… Read more

856. How will transactions related to Iran’s participation in legal proceedings, including administrative, judicial, arbitral proceedings, and proceedings before international courts and tribunals, be treated for purposes of secondary sanctions to the extent that Iranian financial institutions or the Iranian financial sector sanctioned under Executive Order (E.O.) 13902 are involved?

856 … Transactions and activities involving Iranian financial institutions blocked under E.O. 13902 remain authorized under General License (GL) L to the extent they are authorized, exempt, or otherwise not prohibited by the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR… Read more

932. Do U.S. sanctions prohibit U.S. persons from visiting, or making donations to, the Imam Reza Holy Shrine in Mashhad, Iran?

932 … URGENT NOTE: The U.S. Department of State cautions against any travel by U.S. persons to Iran. The Department of State has issued a Level Four Travel Advisory ( Do Not Travel ) for Iran due to the risk of kidnapping, arbitrary arrest, and detention of U.S. citizens . See additional guidance… Read more

1119. Does General License (GL) O authorize all wind-down transactions for any vessel that was blocked on March 2, 2023? What if the vessel contains Iranian-origin merchandise?

1119 … Iran GL O authorizes U.S. persons to wind down all transactions otherwise prohibited by section 5 of Executive Order 13846 involving any vessel blocked as part of the March 2, 2023 designation (“blocked vessels”), subject to certain conditions. This includes, among other activities, the… Read more

1120. Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized to engage in under Iran General License (GL) O?

1120 … No. Non-U.S. persons generally do not risk exposure to sanctions for engaging in activities or facilitating transactions for such activities that would be authorized for U.S. persons pursuant to GL O . Non-U.S. persons unable to wind down transactions in accordance with Iran GL O before 12… Read more

1134. What is the humanitarian channel in Qatar?

1134 … The humanitarian channel in Qatar (HC) was established to further facilitate the flow of humanitarian assistance to the people of Iran consistent with the U.S. government’s longstanding support for humanitarian trade. Similar to humanitarian channels established under previous… Read more

1135. How can companies participate in the humanitarian channel in Qatar to export humanitarian goods to Iran?

1135 … Financial institutions participating in the humanitarian channel in Qatar (HC) have received specific guidance from the U.S. government. Companies interested in participating in transactions under the HC should coordinate directly with the Qatari International Media Office at info@imo.gov.… Read more

1110. What are key changes made by the May 17, 2024, amendment to 31 CFR § 560.540 in comparison to Iran General License D-2?

1110 … On May 17, 2024, OFAC amended 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) to incorporate the provisions of General License (GL) D-2 into 31 CFR § 560.540, with certain additional amendments. Section 560.540 supersedes GL D-2, which OFAC issued on September… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence