Frequently Asked Questions

214. What is the licensing process for U.S. financial institutions that need to conduct transactions in order to close correspondent or payable-through accounts with a foreign financial institution sanctioned pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA)?

… Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . Treasury regulations … accounts with a foreign financial institution sanctioned pursuant to the Comprehensive Iran Sanctions,… Read more

601. Does E.O. 13846 expand the scope of sanctions that were in effect prior to January 16, 2016 (Implementation Day of the JCPOA)?

… effect prior to January 16, 2016 and provides for greater consistency in the administration of Iran-related sanctions provisions. See FAQ 597 . These added measures are as follows: i. … to subsection 1(a)(ii)); or c. Being part of the energy, shipping, or shipbuilding sectors of… Read more

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

805. Are non-U.S. persons exposed to sanctions for providing goods or services to, or engaging in other transactions with, a non-Iranian person sanctioned under section 3 of E.O. 13846?

… transaction for a person on the SDN List that has been designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, … Guard Corps (IRGC), or other activity for which sanctions have been imposed with respect to … Read more

811. Can I ship agricultural commodities, food, medicine, and medical devices to Iran via IRISL or E-Sail on or after June 8, 2020?

… that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran by U.S. and non-U.S. persons (see, e.g., FAQ 637 ). However, these authorizations and … that knowingly engage in certain transactions with IRISL or E-Sail, even for the sale to… Read more

211. If a foreign financial institution continues to do business with Bank of Kunlun, could that lead to a CISADA finding against the other institution?

… Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . Any foreign financial … behalf of designated Iranian banks – whether directly or indirectly – may face Comprehensive Iran… Read more

154. How does the Treasury Department determine whether a transaction or financial service is “significant” for purposes of the Iranian Financial Sanctions Regulations (IFSR)?

… transaction(s) and a blocked Islamic Revolutionary Guard Corps individual or entity or blocked Iran-linked financial institution; (4) the impact of the transaction(s) on the goals of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA… Read more

304. Are there exceptions to insuring, reinsuring, or underwriting sanctioned activities?

… Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran or for the provision of humanitarian assistance to the people of Iran can be insured, reinsured, or underwritten. b. A person that provides insurance, … Transactions… Read more

853. Can U.S. academic institutions provide online learning services to Iranian students located outside the United States? Can U.S. technology companies provide software and services to assist Iranian students in accessing online coursework?

… academic institutions, including their contractors, to export services to students located in Iran, or located outside of Iran but who are ordinarily resident in Iran (“Iranian students”), to sign up for and participate in certain undergraduate… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence