Frequently Asked Questions

165. To what extent are U.S. persons expected to conduct enhanced due diligence to determine if transactions contain a Government of Iran interest?

E.O. 13599 requires U.S. persons to block all property and interests in property of the Government of Iran, unless otherwise exempt or authorized by OFAC. Please contact the OFAC Compliance Hotline , for guidance regarding entities that you suspect are owned or controlled by the Government of Iran… Read more

488. Are goods that are unloaded from a ship in an Iranian port, moved within the boundaries of the port, and loaded onto a second ship en route to a destination outside of Iran, without ever leaving the port considered to be Iranian-origin goods?

No, provided that they have not otherwise come in contact with Iran. …

166. OFAC’s SDN List contains a list of entities identified by OFAC as being the Government of Iran. Should U.S. persons now block the property and interests in property of those entities?

Yes, U.S. persons should now block the property and interests in property of the Government of Iran entities appearing on the SDN List , unless OFAC has authorized the underlying transaction or the transaction is …

167. OFAC has granted my company a license under the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”) and the Iranian Transactions Regulations (ITR). Can I continue to conduct the licensed transaction?

Under General License A issued pursuant to E.O. 13599 , transactions authorized under existing specific licenses issued pursuant to TSRA and the ITR are authorized under E.O. 13599 until the specific license expires, per the terms of the …

168. OFAC has issued me a (non-TSRA) specific license related to Iran, or the Government of Iran. Can I continue to conduct the licensed transactions?

Under General License A issued pursuant to E.O. 13599 , transactions authorized by (non-TSRA) specific licenses issued prior to the issuance of E.O. 13599 and issued pursuant to any part of 31 C.F.R. chapter V are also authorized under E.O. 13599. As set forth in General License A, in most cases… Read more

169. What is the NDAA?

On December 31, 2011, the President signed into law the National Defense Authorization Act ( NDAA ). Section 1245 of the NDAA requires the President to block the property and interests in property subject to U.S. jurisdiction of all Iranian financial institutions, including the Central Bank of Iran… Read more

170. What activities can trigger sanctions on a foreign financial institution under the NDAA?

For private financial institutions, the Act mandates that the President sanction those institutions that are found to knowingly conduct or facilitate any significant transactions with a U.S.-designated Iranian financial institution or with the Central Bank of Iran (CBI) – whether for the purchase… Read more

171. Does the NDAA (National Defense Authorization Act) repeal or amend Section 104(c) of CISADA (the Comprehensive Iran Sanctions, Accountability, and Divestment Act)?

No. Any foreign financial institution that knowingly facilitates significant transactions or provides significant financial services for a U.S.-designated, Iranian-linked financial institution can be sanctioned under section 104(c) of CISADA and section 561.201 of the Iranian Financial Sanctions… Read more

172. How does Executive Order 13599, “Blocking Property of the Government of Iran and Iranian Financial Institutions,” and the blocking of all Iranian financial institutions affect the financial sanctions provisions in CISADA? Do CISADA sanctions now apply to financial transactions with any Iranian financial institution?

The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) applies to transactions with only those Iranian financial institutions that are designated in connection with Iran’s WMD or terrorism activities and are denoted on OFAC’s List of Specially Designated Nationals and Blocked… Read more

173. Are there any exceptions to the sanctions provisions in the National Defense Authorization Act for Fiscal Year 2012 (as amended) (NDAA for FY 2012)?

Yes. Section 1245 of the NDAA for FY 2012 includes an exception that prohibits the President from imposing sanctions “with respect to any person for conducting or facilitating a transaction for the sale of food, medicine, or medical devices to …

Frequently Asked Questions

Office of Terrorism and Financial Intelligence