Frequently Asked Questions

213. Are United States financial institutions that do not hold correspondent or payable-through accounts for Bank of Kunlun required to block or reject transactions that otherwise involve Bank of Kunlun?

213 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . No. U.S. financial institutions are not required to block or reject financial or trade transactions that involve Bank of Kunlun. That said, we would expect… Read more

214. What is the licensing process for U.S. financial institutions that need to conduct transactions in order to close correspondent or payable-through accounts with a foreign financial institution sanctioned pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA)?

214 … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . Treasury regulations provide a 10-day period in which U.S. financial institutions are authorized to engage in the transactions necessary to close an… Read more

215. What is the difference, in practical effect, between this and a designation under one of your other authorities, like E.O. 13382?

215 … The July 31, 2012 Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) finding prohibits the opening or maintaining of correspondent accounts or payable-through accounts in the United States for Bank of Kunlun. This action does not require the immediate freezing of any… Read more

233. Isn’t the National Iranian Oil Company (NIOC) already subject to sanctions?

233 … Yes. Executive Order 13622 provides for sanctions on foreign financial institutions found to have knowingly conducted or facilitated significant financial transactions with NIOC (except for sales of refined petroleum products to NIOC that fall below the dollar threshold that could trigger… Read more

234. What is the effect of the National Iranian Oil Company (NIOC) determination? Are there CISADA implications?

234 … As a result of the Iran Threat Reduction and Syria Human Rights Act (TRA) section 312 determination, NIOC now is also a person described under section 104(c)(2)(E)(i) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) as an agent or affiliate of the IRGC… Read more

235. What are the implications for petroleum purchase transactions involving NIOC by financial institutions and entities in countries that have received a significant reduction exception from the Secretary of State?

235 … Significant transactions, financial services, or material support involving National Iranian Oil Company (NIOC) for the purchase of Iranian petroleum or petroleum products by a foreign financial institution or entity based in a country that has received a significant reduction exception from… Read more

236. Does the determination regarding the National Iranian Tanker Company (NITC) mean that there is no affiliation between NITC and the Iranian Revolutionary Guard Corps (IRGC)?

236 … This statement means only that, based on the currently available information, Treasury is not able to determine at this time that NITC is an agent or affiliate of the IRGC. … Does the determination regarding the National Iranian Tanker Company (NITC) mean that there is no affiliation between… Read more

237. How does the effect of this determination compare to the effect of section 1(a) of Executive Order 13622 as to transactions with National Iranian Oil Company (NIOC)?

237 … The effect of the determination is similar to the effect of Executive Order 13622 section 1(a), which provides for prohibitions on the opening of and prohibitions or strict conditions on maintaining correspondent accounts or payable-through accounts in the United States for foreign financial… Read more

241. What are the major changes that the Iranian Transaction and Sanctions Regulations (ITSR) implement in superseding the Iranian Transaction Regulations (ITR)?

241 … The ITSR block the property and interests in property of the Government of Iran and all Iranian financial institutions that come within the possession or control of any U.S. person, including any foreign branch, and prohibit all U.S. persons from dealing with any property interests whatsoever… Read more

242. The ITSR includes revisions to the ITR pertaining to the transfer of funds to or from Iran. Accordingly, how may I transfer funds to or from Iran that arise from, and are ordinarily incident and necessary to give effect to, an underlying transaction that is authorized under the ITSR?

242 … The Iranian Transactions and Sanctions Regulations (ITSR) authorize United States depository institutions to process transfers of funds to or from Iran, or for the direct or indirect benefit of persons in Iran or the Government of Iran , if the transfer arises from, and is ordinarily incident… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence