Frequently Asked Questions

602 … To provide clarity and consolidate relevant authorities into a single document, E.O. 13846 revokes E.O.s 13716 and 13628, and continues in effect relevant provisions from those two revoked E.O.s. See FAQ 597  and FAQ 598 . Provisions of E.O. 13846 that carry forward relevant provisions of E.O… Read more

603 … Yes. OFAC is taking action under section 7 of E.O. 13846 to continue in effect the designations of persons who were designated pursuant to E.O. 13628 at the time of the issuance of E.O. 13846. See FAQ 602 . U.S. persons must continue to block the property and interests in property of these… Read more

604 … The Treasury Department implementation authorities set out in section 1 of E.O. 13574 for “menu-based” sanctions under ISA have been superseded by the implementation authorities for “menu-based” sanctions under a broader range of authorities that include ISA , CISADA , TRA , and IFCA , and… Read more

605 … E.O. 13846 implements provisions of, and provides additional tools related to, ISA , CISADA , TRA , and IFCA that were contained in the prior E.O.s. These include: i. Invoking the President’s authority under the International Emergency Economic Powers Act (IEEPA) to supplement statutory… Read more

606 … After the 90-day wind-down period ends on August 6, 2018, the following sanctions come into effect, including under provisions of E.O. 13846 and relevant statutory authorities: i. Sanctions on the purchase or acquisition of U.S. dollar banknotes by the GOI (see, e.g., subsection 1(a)(i) of E.… Read more

607 … After the 180-day wind-down period ends on November 4, 2018, the following sanctions come into effect, including under provisions of E.O. 13846 and relevant statutory authorities: i. Sanctions on Iran’s port operators, and shipping and shipbuilding sectors, including on the Islamic Republic… Read more

608 … Section 6 of E.O. 13846 reimposes the sanctions previously contained in section 1 of E.O. 13645 with respect to transactions involving the Iranian rial. FFIs risk correspondent and payable-through account sanctions and blocking sanctions if they, on or after August 7, 2018, (i) knowingly… Read more

263 … In order for the National Defense Authorization Act's ( NDAA ) significant reduction exception to apply on or after February 6, 2013, the person receiving payment (e.g., the manufacturer or service provider) for goods or services being exported to Iran must be – (i) a citizen, national, or… Read more

264 … No. If funds from the RECIPIENT ACCOUNT or the SPECIAL PURPOSE ACCOUNT are remitted, directly or indirectly, to Iran, or paid to any person that is the GOI , the FFI would be exposed to sanctions. … Can funds be remitted to Iran or the Government of Iran (GOI) without exposure to …

265 … The National Defense Authorization Act of Fiscal Year 2012 (NDAA) generally exempts from sanctions sales made under the Humanitarian Exception (i.e., the sale of agricultural commodities, food, medicine, or medical devices from third countries to Iran). Funds deposited in the RECIPIENT… Read more