Frequently Asked Questions

300 … Pursuant to delegated authority, the Secretary of State issues periodic reports pursuant to section 1245(e) of IFCA with respect to which sectors of the Iranian economy are controlled directly or indirectly by Iran’s Islamic Revolutionary Guard Corps (IRGC). Given the opaque business… Read more

301 … A FFI , prior to conducting or facilitating a significant financial transaction for the sale, supply, or transfer to or from Iran of the materials listed in 1245(d) – as described in part in Q&A 298 – will need to undertake due diligence to ensure that the transaction does not involve the… Read more

302 … A person will not be subject to sanctions under section 1245 of IFCA if a determination is made by the Department of the Treasury or the Department of State, as appropriate, that the person has established and enforced official policies, procedures, and controls to ensure that the person does… Read more

303 … A number of insurance activities are subject to sanctions under IFCA , including knowingly providing insurance, reinsurance, or underwriting services to or for Iranian persons on the SDN List to or for any person designated in connection with Iran’s support for international terrorism or WMD… Read more

266 … Yes. On September 24, 2012, NIOC was identified as an agent or affiliate of Iran’s Islamic Revolutionary Guard Corps (“IRGC”) under section 312 of the TRA , and designated on November 8, 2012, under E.O. 13382 for providing services and support to the IRGC. Accordingly, the Comprehensive Iran… Read more

609 … E.O. 13846 reimposes the sanctions previously contained in subsections 3(a)(ii) and section 5 of E.O. 13645 by authorizing the imposition of correspondent and payable-through account sanctions (subsection 2(a)(i)) of E.O. 13846) and menu-based sanctions (subsection 3(a)(i) of E.O. 13846) for… Read more

610 … E.O. 13846 defines the automotive sector of Iran as the manufacturing or assembling in Iran of light and heavy vehicles including passenger cars, trucks, buses, minibuses, pick-up trucks, and motorcycles, as well as original equipment manufacturing and after-market parts manufacturing… Read more

611 … E.O. 13846 reimposes sanctions on certain transactions on or after August 7, 2018, for the sale, supply, or transfer to Iran of “significant” goods or services used in connection with the automotive sector of Iran. (See FAQ 289 for an interpretation of the term “significant.”) We anticipate… Read more

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 … 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