Frequently Asked Questions

186. How do I know that a person has been designated under the GHRAVITY E.O.?

186 … Persons designated under the GHRAVITY E.O. appear on the publicly available Specially Designated Nationals List ( SDN list ) bearing the [HRIT] tag. U.S. persons are obligated to block property involving the persons bearing the tag [HRIT] on the SDN list, unless the transaction is exempt or… Read more

187. Does the GHRAVITY E.O. prohibit me from exporting technology to companies that do business with Iran or Syria?

187 … This E.O. does not generally prohibit transactions involving persons that do business with Iran or Syria, unless the person has been designated pursuant to this order. You should consult with the Department of Commerce’s Bureau of Industry and Security (BIS) regarding exports to companies… Read more

188. If I am a non-U.S. company that exports information and communications technology to Iran or Syria, will I be designated under the GHRAVITY E.O.?

188 … The measures in this order are designed primarily to address the need to prevent entities located in whole or in part in Iran and Syria from facilitating or committing serious human rights abuses. These measures are not designed to prevent the provision of information and communications… Read more

189. Would I need authorization from OFAC or BIS if I wanted to export goods or technology to persons blocked under the GHRAVITY E.O.?

189 … Yes. For more information regarding exports of goods or technology to persons blocked under the GHRAVITY E.O. please contact OFAC or BIS. … Would I need authorization from OFAC or BIS if I wanted to export goods or technology to persons blocked under the GHRAVITY …

621. What is the prohibition on U.S.-owned or -controlled foreign entities, and how does it work?

621 … Consistent with Section 218 of TRA , section 8 of E.O. 13846 continues in effect the sanctions previously contained in section 4 of E.O. 13628 and expands them to cover activity sanctionable under E.O. 13846 (see FAQ 601 ). This provision prohibits a U.S.-owned or -controlled foreign entity… Read more

825. How can parties participate in the Swiss Humanitarian Trade Arrangement (SHTA) to export humanitarian goods to Iran?

825 … The SHTA is overseen by Switzerland’s State Secretariat for Economic Affairs (SECO) and intended for use by U.S. and non-U.S. persons domiciled in Switzerland. Exporters within Swiss jurisdiction may reach out to SECO at SHTA@seco.admin.ch for further details on requirements and instructions… Read more

821. What does General License No. 8A (GL 8A) authorize with respect to humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC)?

821 … As a result of the CBI and NIOC's designations pursuant to Executive Order 13224 , as amended (E.O. 13224), U.S. persons are prohibited from engaging in any transaction or dealing in the property or interests in property of the CBI or NIOC under the Global Terrorism Sanctions Regulations, 31… 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.qa… Read more

822. I'm a U.S. person that relied on general or specific licenses pursuant to 560.530, 560.532, or 560.533 of the ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. 13224, as amended. Is any further authorization needed to conduct such transactions following the designations of the CBI and NIOC under E.O. 13224?

822 … No. As detailed in FAQ 821 , GL 8A authorizes certain humanitarian-related transactions and activities involving the CBI, NIOC, or any entity in which NIOC owns a 50 percent or greater interest, that would be prohibited by the GTSR or by the ITSR due to the exclusion at section 560.530(d)(5)… 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

Frequently Asked Questions

Office of Terrorism and Financial Intelligence