Frequently Asked Questions

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

… that OFAC had previously identified as meeting the definition of the terms “Government of Iran” or “Iranian financial institution” still met those definitions and continued to be persons … transactions for the sale of agricultural commodities, food, medicine, or medical devices… Read more

210. What are the consequences for a U.S. financial institution that maintains or opens a new correspondent or payable-through account for Bank of Kunlun?

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

185. What type of activities does the GHRAVITY E.O. target?

… could assist in or enable serious human rights abuses by or on behalf of the Government of Iran or the Government of Syria. It is not intended to block exports of technology that enable … could assist in or enable serious human rights abuses by or on behalf of the Government of… Read more

260. What is a SPECIAL PURPOSE ACCOUNT for purposes of the National Defense Authorization Act's (NDAA) significant reduction exception?

… that require the account to be used only for bilateral trade in goods or services between Iran and the country with primary jurisdiction over the FFI , and for sales made under the … that require the account to be used only for bilateral trade in goods or services between… Read more

608. What transactions involving the Iranian rial are sanctionable under E.O. 13846?

… of the Iranian rial, or (ii) maintain significant funds or accounts outside the territory of Iran denominated in the Iranian rial. … of the Iranian rial, or (ii) maintain significant funds or accounts outside the territory of Iran denominated in the Iranian rial… Read more

213. Are United States financial institutions that do not hold correspondent or payable-through accounts for Bank of Kunlun required to block or reject transactions that otherwise involve Bank of Kunlun?

… Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA) . No. U.S. financial … Context Information: This FAQ is associated with the Comprehensive Iran Sanctions, Accountability, and… Read more

633. Under what circumstances are goods or services considered “fully provided or delivered” prior to the expiration of the relevant wind-down period, as referenced in FAQ 631 above?

… for payment or other agreed-to compensation. With respect to goods exported to or from Iran, at a minimum, title to the goods must have transferred to the relevant party … for payment or other agreed-to compensation. With respect to goods exported to or from Iran… 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?

… a non-designated Iranian financial institution – or a person designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, … entry in addition to the tag for the other sanctions program(s) (e.g., the “[SDGT]” tag, the… Read more

624. What are the implications of subsection 1(a)(iii) of E.O. 13846?

… appropriate steps to avoid, among other things, undue impacts on the access of the people of Iran to humanitarian items, telecommunications, and other basic services. … appropriate steps to avoid, among other things, undue impacts on the access of the people of Iran… Read more

346. What kind of due diligence is required for the exportation of fee-based services, software, or hardware authorized by 31 CFR § 560.540?

… to any sanctions program administered by OFAC, regardless of whether the Government of Iran or other end-user appears on OFAC’s Specially Designated Nationals and Blocked Persons List … to any sanctions program administered by OFAC, regardless of whether the Government of… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence