Frequently Asked Questions

189. Would I need authorization from OFAC or BIS if I wanted to export goods or technology to persons blocked under the GHRAVITY E.O.?

189 … Yes. For more information regarding exports of goods or technology to persons blocked under the GHRAVITY E.O. please contact OFAC or BIS. … Would I need authorization from OFAC or BIS if I wanted to export goods or technology to persons blocked under the GHRAVITY …

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

118. I have a client that is in Iran to visit a relative. Do I need to restrict the account?

118 … No. As long as you are satisfied that the client is not ordinarily resident in Iran, then the account does not need to be restricted. See FAQ 37 . … I have a client that is in Iran to visit a relative. Do I need to restrict the …

54. I have an account with a W-8 showing an address in Iran. Is the account automatically restricted?

54 … In the absence of information proving to your satisfaction that the account holder is not in Iran, you should consider the account restricted based on the W-8 filing. See FAQ 37 . … I have an account with a W-8 showing an address in Iran. Is the account automatically …

533. What are the requirements of CAATSA section 105 related to the imposition of sanctions on the IRGC, and how are those requirements being implemented?

533 … On August 2, 2017, the President signed into law the “Countering America’s Adversaries Through Sanctions Act” (Public Law 115-44) ( CAATSA ), which, among other things, imposes new sanctions on Iran. Section 105 of CAATSA requires the imposition of sanctions applicable pursuant to the global… Read more

534. Before October 13, 2017, wasn’t the IRGC already subject to sanctions? What’s different about applying terrorism-related sanctions to the IRGC and foreign persons that are officials, agents, or affiliates of the IRGC?

534 … Before October 13, 2017, the IRGC was blocked under Executive Order 13382 (relating to WMD proliferation), 13553 (relating to Iranian human rights abuses), and 13606 (relating to Iranian and Syrian human rights abuses via information technology), and persons who engaged in certain activity… Read more

260. What is a SPECIAL PURPOSE ACCOUNT for purposes of the National Defense Authorization Act's (NDAA) significant reduction exception?

260 … A SPECIAL PURPOSE ACCOUNT is an account set up with conditions and safeguards that require the account to be used only for bilateral trade in goods or services between Iran and the country with primary jurisdiction over the FFI , and for sales made under the Humanitarian Exception (see FAQ… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence