Frequently Asked Questions

184. What does the GHRAVITY E.O. do?

… could assist in or enable serious human rights abuses by or on behalf of the Government of Iran or the Government of Syria; or (2) to have sold, leased, or otherwise provided, directly or indirectly, goods, services, or technology to Iran or Syria likely to be… 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

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

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?

… 1087 … 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… 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?

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

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

… 241 … 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

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

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

671. How are the terms “significant transaction or transactions; significant financial services; significant financial transaction” interpreted for purposes of correspondent or payable-through account sanctions set forth in section 2 of E.O. 13871?

… practices; (g) whether the transactions solely involve the passive holdings of Central Bank of Iran (CBI) reserves or repayment by the CBI of official development assistance or the transfer of funds required as a condition of Iran’s membership in an international… Read more

234. What is the effect of the National Iranian Oil Company (NIOC) determination? Are there CISADA implications?

… 234 … As a result of the Iran Threat Reduction and Syria Human Rights Act (TRA) section 312 determination, NIOC now is also a person described under section 104(c)(2)(E)(i) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA)… 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.” … Are there any exceptions to the sanctions provisions in the National Defense …

Frequently Asked Questions

Office of Terrorism and Financial Intelligence