Frequently Asked Questions

483. How does an exporter determine which medical devices need to be specifically licensed by OFAC for exportation or reexportation to Iran?

483 … An exporter should refer to the List of Medical Devices Requiring Specific Authorization , which is maintained on OFAC’s website, on the Iran Sanctions page . An exporter must obtain a specific license from OFAC to export or reexport any medical device on that list to Iran. An exporter must… Read more

484. What types of training activities are considered to be necessary and ordinarily incident to the safe and effective use of medicine and medical devices?

484 … OFAC considers training activities including the dissemination of product information on the intended use of the device; comparisons of other devices and options; and the manufacturer’s instructions for use, labeling, warning, contraindications, storage, and maintenance of the medicine or… Read more

485. What key changes did the December 23, 2016 regulatory amendment to the Iranian Trade and Sanctions Regulations (ITSR) make to the definition of “Iranian-origin goods” or “goods of Iranian origin”?

485 … OFAC amended section 560.306 of the ITSR to clarify that the terms “goods of Iranian origin” and “Iranian-origin goods” do not include the following categories of goods, provided that such goods were not grown, produced, manufactured, extracted, or processed in Iran: (i) goods exported or… Read more

486. What is an example of goods otherwise coming into contact with Iran?

486 … Goods have come into contact with Iran, if, for example, they are removed from a port or airport in Iran or are processed through Iranian customs, or if they transit Iran by truck or train en route to a destination outside of Iran. … What is an example of goods otherwise coming into contact… Read more

620. What are the definitions of "petroleum products" and "petrochemical products"?

620 … The term "petroleum products," as defined in section 16(o) of E.O. 13846 , includes unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical… Read more

634. Can I, as a non-U.S., non-Iranian person, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period pursuant to contracts entered into prior to May 8, 2018?

634 … Yes, subject to the conditions set out below and in FAQ 631 above, non-U.S., non-Iranian persons may receive payment after the end of the relevant wind-down period for goods or services fully provided or delivered to an Iranian counterparty prior to expiration of the relevant wind-down period… Read more

635. Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period under an OFAC wind-down authorization and pursuant to a contract entered into prior to May 8, 2018?

635 … The wind-down authorizations allow U.S. persons and U.S.-owned or -controlled foreign entities to receive payments for activities conducted pursuant to such wind-down authorizations only during their validity periods. For example, a U.S.-owned or -controlled foreign entity may receive payment… Read more

636. Can I receive payment for activities undertaken during the wind-down period if the payment involves a person that has been added to the SDN List, including a person that was previously on the List of Persons Blocked Solely Pursuant to E.O. 13599 (the “E.O. 13599 List”) but is now designated under another authority?

636 … The United States intends to fully enforce the sanctions that apply to persons that were previously on the E.O. 13599 List but that are now designated under another authority. U.S. persons and U.S.-owned or -controlled foreign entities generally would require an OFAC authorization to receive… Read more

637. Is it sanctionable for non-U.S., non-Iranian persons to engage in transactions related to the provision of humanitarian and consumer goods to Iran?

637 … The United States maintains broad authorizations and exceptions under U.S. sanctions that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran from the United States or by U.S. persons or U.S.-owned or -controlled foreign entities. U.S. sanctions laws… Read more

638. What happened to the E.O. 13599 List?

638 … The E.O. 13599 List was created to clarify that, regardless of their removal from the SDN List on January 16, 2016, persons that OFAC had previously identified as meeting the definition of the terms “Government of Iran” or “Iranian financial institution” still met those definitions and… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence