Frequently Asked Questions

614. What does E.O. 13846 do with respect to Iran’s energy, petroleum, and petrochemical sectors?

614 … E.O. 13846 reimposes sanctions previously set out in E.O.s 13622, 13628, and 13645 with respect to the Iranian energy, petroleum, and petrochemical sectors. As such, subsections 1(a)(ii) and (2)(a)(ii) of E.O. 13846 authorize blocking sanctions and correspondent or payable-through account… Read more

615. Does E.O. 13846 mean that Iran’s trade partners should no longer buy petroleum products from Iran? How will this affect exports of Iranian oil?

615 … These measures, which apply to transactions occurring on or after November 5, 2018, establish a key element of the comprehensive Iran sanctions framework by deterring work-around financial transactions involving NIOC or NICO that were not being captured under the sanctions previously… Read more

616. Can countries that receive a significant reduction exception under NDAA 2012 purchase oil through NIOC and NICO without facing sanctions?

616 … All property and interests in property of NIOC and NICO subject to U.S. jurisdiction are already blocked pursuant to E.O. 13599, and U.S. persons are prohibited from all dealings with these entities. E.O. 13846 reestablishes the authority previously contained in E.O. 13622 to sanction FFIs… Read more

617. E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or NICO subsidiary? Are transactions with those entities also sanctionable under this E.O.?

617 … Yes. As in E.O. 13622, E.O. 13846 defines NIOC and NICO to include any entity owned or controlled by, or operating for or on behalf of, NIOC and NICO. … E.O. 13846 targets transactions between foreign financial institutions and NIOC and NICO. What about a NIOC or NICO subsidiary? Are… Read more

618. Does E.O. 13846 make sanctionable activities related to the pipeline project to supply natural gas from the Shah Deniz gas field in Azerbaijan to Europe and Turkey, given that NICO reportedly has a 10 percent stake in the project?

618 … No. Section 10 of E.O. 13846 maintains the exceptions previously provided for in E.O. 13622 and E.O. 13645, as well as in subsection 603(a) of the TRA and section 1254 of IFCA, for the pipeline project to supply natural gas from the Shah Deniz gas field in Azerbaijan to Europe and Turkey. …… Read more

619. Are barter arrangements or other non-cash trade transactions involving petroleum, petroleum products, or petrochemical products originating from Iran sanctionable under the terms of E.O. 13846?

619 … Yes. To the extent a financial institution is involved, that financial institution could be sanctioned under E.O. 13846 for a barter arrangement, on or after November 5, 2018, related to the purchase or acquisition of petroleum, petroleum products, or petrochemical products from Iran. In… Read more

620. What are the definitions of "petroleum products" and "petrochemical products"?

620 … The term "petroleum products," as defined in section 16(o) of E.O. 13846 , includes unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical… Read more

634. Can I, as a non-U.S., non-Iranian person, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period pursuant to contracts entered into prior to May 8, 2018?

634 … Yes, subject to the conditions set out below and in FAQ 631 above, non-U.S., non-Iranian persons may receive payment after the end of the relevant wind-down period for goods or services fully provided or delivered to an Iranian counterparty prior to expiration of the relevant wind-down period… Read more

635. Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period under an OFAC wind-down authorization and pursuant to a contract entered into prior to May 8, 2018?

635 … The wind-down authorizations allow U.S. persons and U.S.-owned or -controlled foreign entities to receive payments for activities conducted pursuant to such wind-down authorizations only during their validity periods. For example, a U.S.-owned or -controlled foreign entity may receive payment… Read more

636. Can I receive payment for activities undertaken during the wind-down period if the payment involves a person that has been added to the SDN List, including a person that was previously on the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) but is now designated under another authority?

636 … The United States intends to fully enforce the sanctions that apply to persons that were previously on the E.O. 13599 List but that are now designated under another authority. U.S. persons and U.S.-owned or -controlled foreign entities generally would require an OFAC authorization to receive… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence