Frequently Asked Questions

258. What is meant by the TRA section 504’s requirement that bilateral trade consist of trade in goods and services between the country with primary jurisdiction over the foreign financial institution (FFI) and Iran?

258 … OFAC interprets bilateral trade between Iran and the country with primary jurisdiction over the FFI to mean trade in only those goods or services originating in (e.g., produced in or substantially transformed in) – (i) the country with primary jurisdiction over the FFI conducting or… Read more

340. What should I do if I am unsure whether an item or service is covered by 31 CFR § 560.540?

340 … If you require assistance interpreting the authorizations contained in 31 CFR § 560.540 and how they apply to your situation, please contact OFAC’s Compliance hotline or submit a request for interpretive guidance at the OFAC License Application Page . Date Updated: May 16, 2024 … What should… Read more

341. May a non-U.S. person export, reexport, or provide to Iran hardware or software that is subject to Commerce's Export Administration Regulations (EAR) pursuant to 31 CFR § 560.540?

341 … Yes. For purposes of the authorities administered by OFAC, 31 CFR § 560.540 authorizes the exportation, reexportation, or provision of certain hardware and software subject to the EAR by non-U.S. persons outside the United States. See 31 CFR § 560.540(a)(2)(i) and (a)(3). For example, a… Read more

342. Does 31 CFR § 560.540 continue to authorize U.S. persons located outside the United States to export or reexport to Iran certain specified hardware or software that is not subject to Commerce's Export Administration Regulations (EAR)?

342 … Yes. Section 560.540 of the ITSR continues to authorize the exportation, reexportation, or provision to Iran by U.S. persons located outside of the United States of certain specified hardware and software items that are not subject to the EAR . See 31 CFR § 560.540(a)(2)(ii), (a)(3)(ii) and… Read more

343. Does 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the exportation to Iran and importation into the United States or a third country of communication devices by persons travelling to and from Iran?

343 … Yes. Section 560.540 of the ITSR authorizes the exportation, reexportation, or provision to Iran and the importation into the United States by an individual entering the United States directly or indirectly from Iran, of hardware and software authorized by paragraphs 31 CFR § 560.540(a) (2)… Read more

455. Is the provision of routine goods and services by non-U.S. persons to diplomatic missions of the Government of Iran located outside the United States sanctionable under U.S. law?

455 … The provision of goods and services for the conduct of the official business of the diplomatic missions of the Government of Iran located outside the United States or for the personal use of the employees of the missions, including financial services such as the opening of a bank account, by… Read more

37. My bank operates accounts for individuals living in Iran. OFAC has told us that these accounts cannot be operated. Does this mean that the accounts are blocked?

37 … No, the accounts are restricted. The Iranian sanctions prohibit the export of goods or services to Iran. By operating an account for an individual or company in Iran, the bank would be exporting services to that person or entity in violation of the Iranian Transactions Regulations. The… Read more

38. Are U-Turn payments for Iran still permitted?

38 … No, as of November 10, 2008 U-Turn payments are no longer allowed. … Are U-Turn payments for Iran still permitted? …

682. What does the August 06, 2019 regulatory amendment related to E.O. 13871 do?

682 … The regulatory amendment: (i) implements the correspondent or payable-through account sanctions set forth in section 2 of E.O. 13871 by incorporating those provisions in the Iranian Financial Sanctions Regulations, 31 C.F.R. part 561 (IFSR); (ii) renames the Iranian Human Rights Regulations,… Read more

318. Does the GL for medical devices authorize the exportation or reexportation of all medical devices?

318 … No. The GL for medical devices appearing at section 560.530 (a)(3)(i) of the Iranian Transactions and Sanctions Regulations ( ITSR ) authorizes covered persons, as defined in section 560.530(e)(4), to export or reexport to Iran medical devices as defined in section 560.530(e)(3) of the ITSR,… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence