Frequently Asked Questions

630. Is the provision or delivery of goods or services to an Iranian counterparty after November 4, 2018 allowed?

… that allow for the sale of agricultural commodities, food, medicine, and medical devices to Iran by U.S. persons and non-U.S. persons. However, these authorizations and exceptions do not … Nationals and Blocked Persons (SDN List) that have been designated in connection with… Read more

233. Isn’t the National Iranian Oil Company (NIOC) already subject to sanctions?

… products to NIOC that fall below the dollar threshold that could trigger sanctions under the Iran Sanctions Act ). Executive Order 13622 also provides authority for the Secretary of the … Executive Order 13622. In addition, NIOC was already blocked as an entity of the Government… Read more

158. Can the application of any part(s) of the Iranian Financial Sanctions Regulations (IFSR) be waived by the Department of the Treasury?

… The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) provides for a waiver of the … The Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) provides for a waiver of the …

179. Does the definition of “significant financial transaction” exclude the passive holding of Central Bank of Iran (CBI) reserves? Is the U.S. willing to give assurances that this will not be a basis for sanctions?

… of “significant financial transaction” exclude the passive holding of Central Bank of Iran (CBI) reserves? Is the U.S. willing to give assurances that this will not be a basis for … of “significant financial transaction” exclude the passive holding of Central Bank of Iran… Read more

191. What does Executive Order 13608 “Prohibiting Certain Transactions with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to Iran and Syria” do?

… to violate, conspired to violate, or caused a violation of U.S. sanctions on Syria or Iran. This E.O. also gives Treasury the authority to impose sanctions on foreign persons who have … with and Suspending Entry into the United States of Foreign Sanctions Evaders with Respect to… Read more

173. Are there any exceptions to the sanctions provisions in the National Defense Authorization Act for Fiscal Year 2012 (as amended) (NDAA for FY 2012)?

… conducting or facilitating a transaction for the sale of food, medicine, or medical devices to Iran.” … conducting or facilitating a transaction for the sale of food, medicine, or medical devices to Iran.” …

212. Does this finding affect Bank of Kunlun's branches or subsidiaries around the world? Does this finding affect any holding companies?

… Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . The prohibitions … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and… Read more

241. What are the major changes that the Iranian Transaction and Sanctions Regulations (ITSR) implement in superseding the Iranian Transaction Regulations (ITR)?

… The ITSR block the property and interests in property of the Government of Iran and all Iranian financial institutions that come within the possession or control of any … of the Federal Government and the property and interests in property of the Government of Iran… Read more

1087. Does the general license at 31 CFR § 560.540 authorize the exportation of fee-based or no-cost cloud-based services and software to Iran that are used to support communications tools authorized by 31 CFR § 560.540?

… Yes. Section 560.540(a)(1) of the ITSR authorizes the exportation to Iran of fee-based or no-cost cloud-based services incident to the exchange of communications over the internet. In addition, 31 CFR § 560.540(a)(2) authorizes the exportation to Iran of cloud-… Read more

177. If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise acting solely as an intermediary in a transaction between a non-designated Iranian bank and a foreign financial institution, is the foreign financial institution deemed to be engaging in a transaction with the CBI?

… If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise acting … If the Central Bank of Iran (CBI) is involved in providing settlement services for a transaction, or is otherwise acting …

Frequently Asked Questions

Office of Terrorism and Financial Intelligence