Frequently Asked Questions

855. How will transactions related to official activities of international organizations be treated for purposes of secondary sanctions to the extent that the Iranian financial sector or Iranian financial institutions sanctioned under Executive Order (E.O.) 13902 are involved?

… sector, as non-sanctionable: The operating expenses or other official business of missions in Iran of international organizations in which Iran is a member or participant, or for the personal use of employees of the missions; and The operating expenses or other… Read more

302. Are there any exceptions to section 1245 of IFCA?

… and controls to ensure that the person does not sell, supply, or transfer to or from Iran, or facilitate or conduct a significant financial transaction to sell supply, or transfer to or from Iran, materials listed in section 1245 as sanctioned under section 1245… Read more

603. Do persons who were designated pursuant to E.O. 13628 of October 9, 2012, “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 and Additional Sanctions With Respect to Iran,” continue to be subject to sanctions following the issuance of E.O. 13846?

… of October 9, 2012, “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 and Additional Sanctions With Respect to Iran,” continue to be subject to sanctions following the issuance of E.O.… 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?

… the Secretary of State do not carry potential sanctions consequences – under the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), sections 302 and 312 of the Iran Threat Reduction and Syria Human Rights Act (TRA), section 1245 of the… Read more

600. Why does subsection 1(a)(iv) of E.O. 13846 take effect before November 5, 2018?

… of IFCA on persons determined to: (A) be part of the energy, shipping, shipbuilding sectors of Iran; (B) operate a port in Iran; or (C) knowingly provide significant support to certain other persons sanctioned pursuant … are waived through November 4, 2018 to… Read more

810. On December 11, 2019, the State Department announced that it would designate the Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping Limited (“E-Sail”) under Executive Order (E.O.) 13382, effective June 8, 2020. IRISL and E-Sail are already listed on the SDN List. What will be the impact of the State Department’s designation of these entities under E.O. 13382?

… 810 … On November 5, 2018, OFAC identified IRISL and E-Sail on the SDN List with the [IRAN] tag to indicate that they are entities meeting the definition of the Government of Iran whose property and interests in property are blocked pursuant to E.O. 13599.… Read more

597. What is the purpose of Executive Order (E.O) 13846 of August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran”?

… of the Treasury on May 8, 2018 , E.O. 13846 reimposes specified sanctions relating to Iran following relevant wind-down periods, i.e., on or after August 7, 2018 or November 5, 2018, … Executive Order (E.O) 13846 of August 6, 2018, “Reimposing Certain Sanctions With Respect to… Read more

816. Is there a wind-down period for Executive Order 13902, “Imposing Sanctions with Respect to Additional Sectors of Iran” (E.O. 13902)?

… period for Executive Order 13902, “Imposing Sanctions with Respect to Additional Sectors of Iran” (E.O. 13902)? …

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

… transactions with a U.S.-designated Iranian financial institution or with the Central Bank of Iran (CBI) – whether for the purchase of petroleum or otherwise – unless the transaction is for the sale of food, medicine, or medical devices to Iran. For all… 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)?

… 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 … overseas branch of a U.S. company or a U.S.-owned or -controlled foreign entity may export to… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence