Frequently Asked Questions

267. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “food, medicine, and medical devices,” “foreign financial institution,” and “country with primary jurisdiction over the FFI”?

267 … These definitions are set out in 31 CFR Part 561 . … What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “food, medicine, and medical devices,” “foreign financial institution,” and “country with primary jurisdiction over the …

612. Is the sale, supply, or transfer of finished vehicles or “auto kits” to Iran sanctionable under the New E.O.?

612 … E.O. 13846 does not make sanctionable the export of finished vehicles to Iran if no further assembly or manufacturing is required. As such, exporting fully assembled and finished vehicles to Iran for sale would not be sanctionable, so long as the transaction is consistent with U.S. sanctions… Read more

613. Is the sale, supply, or transfer of goods or services for the maintenance of finished vehicles sanctionable under E.O. 13846?

613 … Goods or services for the maintenance of finished vehicles exported to Iran would generally not be considered “significant goods or services used in connection with the automotive sector of Iran” for the purposes of E.O. 13846 , and the provision of such goods or services would generally not… Read more

313. What is the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA)?

313 … IFCA was signed into law on January 2, 2013, as a part of the National Defense Authorization Act for Fiscal Year 2013, and provides for several new sanctions related to Iran. IFCA authorizes broad sanctions on: certain activities related to Iran’s energy, shipping, and shipbuilding sectors;… 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?

853 … 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… 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?

855 … 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… 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?

856 … 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… Read more

829. Following the Secretary of State’s announcement on May 27, 2020 that he will be ending certain Iran nuclear-related waivers, will there be a wind-down period for persons engaged in activity permitted by these waivers?

829 … Yes. Persons engaged in activities currently permitted by the Department of State’s nuclear-related waivers associated with the Arak reactor modernization redesign, the transfer into Iran of enriched uranium for the Tehran Research Reactor, and the transfer out of Iran of certain nuclear… Read more

830. Will OFAC target Iranian manufacturers of medicines, medical devices, or products used for sanitation or hygiene or as personal protective equipment for use in Iran pursuant to Executive Order (E.O.) 13902 for continuing to manufacture these items? Will OFAC target persons conducting or facilitating transactions for the provision of such items to Iran if the transaction involves a person sanctioned under E.O. 13902?

830 … No. For the purposes of evaluating sanctions pursuant to E.O. 13902 , persons in Iran manufacturing medicines, medical devices, or products used for sanitation, hygiene, medical care, medical safety, and manufacturing safety, including soap, hand sanitizer, ventilators, respirators, personal… Read more

831. How will OFAC define the sectors of the Iranian economy specified in Executive Order (E.O.) 13902 of January 10, 2020?

831 … E.O. 13902 imposes sanctions with respect to any person determined by the Secretary of the Treasury to operate in the construction, mining, manufacturing, and textiles sectors of the Iranian economy, and any additional sectors of the Iranian economy as may be determined by the Secretary of… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence