Frequently Asked Questions

846. How do the sanctions imposed on the Iranian financial sector and Iranian financial institutions (FIs) pursuant to Executive Order (E.O.) 13902 affect waivers issued by the Department of State and exceptions set forth in the Iranian Freedom and Counter-proliferation Act of 2012 (IFCA)?

Waivers issued by the Department of State (State) and exceptions set forth in IFCA remain valid and activities conducted under them involving Iranian FIs are not sanctionable during the wind-down period described in FAQ 845 . Persons engaged in transactions or activities involving the Iranian… Read more

847. As a result of the sanctions on the Iranian financial sector and certain Iranian financial institutions (Iranian FIs) pursuant to Executive Order (E.O.) 13902, do non-U.S. persons risk exposure to sanctions for continuing to engage in previously non-sanctionable trade involving the Iranian financial sector or E.O. 13902-sanctioned Iranian FIs, even after the end of the 45-day wind-down period?

For purposes of E.O. 13902, OFAC would not generally view transactions or activities by non-U.S. persons to be sanctionable if they are consistent with activities that would be permissible if conducted by U.S. persons. As noted in FAQ 842 , General License (GL) L authorizes U.S. persons to engage… 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?

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 accredited… 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?

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. In… 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?

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) . This… Read more

630. Is the provision or delivery of goods or services to an Iranian counterparty after November 4, 2018 allowed?

The wind-down period has ended and the United States intends to fully enforce the sanctions that have come back into effect. The provision or delivery of goods or services and/or the extension of additional loans or credits to an Iranian counterparty after November 4, 2018 — even pursuant to… Read more

631. I was not able to receive payment for goods or services fully provided or delivered prior to the end of the wind-down period.How should I proceed?

In the event that a non-U.S., non-Iranian person is owed payment after the conclusion of the wind-down period on August 6, 2018, or November 4, 2018, as applicable, for goods or services fully provided or delivered to an Iranian counterparty prior to August 6, 2018, or November 4, 2018, as… Read more

632. Will the U.S. government provide assurances beyond the guidance described in 631 and 634 that receipt of payment by non-U.S., non-Iranian persons is not sanctionable?

OFAC encourages non-U.S., non-Iranian persons to rely on the guidance provided in FAQs 631 and 634. Non-U.S., non-Iranian persons can seek guidance from OFAC or the State Department, as appropriate, prior to the receipt of payment, if they would like to confirm that the payments would meet the… Read more

633. Under what circumstances are goods or services considered “fully provided or delivered” prior to the expiration of the relevant wind-down period, as referenced in FAQ 631 above?

OFAC looks to the industry standard to determine whether particular goods or services are considered fully provided or delivered prior to the expiration of the relevant wind-down period. As a general matter, goods or services will be considered fully provided or delivered when the party providing… Read more

598. What does E.O. 13846 do?

E.O. 13846 reimposes relevant blocking sanctions, correspondent and payable-through account sanctions, and menu-based sanctions previously provided for in E.O.s 13574, 13590, 13622, and 13645, which were revoked by E.O. 13716, and continues in effect sanctions authorities provided for in E.O.s… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence