Frequently Asked Questions

290. Are payments or deliveries that are made on or after July 1, 2013, for contracts that existed prior to July 1, 2013, exempted from IFCA provisions?

… to July 1, 2013, on or after which date certain activities become sanctionable under the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA). The assessment of whether such …

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?

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

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 …

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, …

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 …

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. … What transactions involving the Iranian rial are …

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 … Under what …

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 …

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. … What are the …

843. I’m a U.S. person that relied on general or specific licenses issued pursuant to the Iranian Transactions and Sanctions Regulations (ITSR) to conduct humanitarian-related or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. 13902. Is any further authorization needed to conduct such transactions following these actions?

… or other transactions and activities prior to the identification of the financial sector of Iran and sanctioning of a number of Iranian financial institutions (Iranian FIs) under E.O. …

Frequently Asked Questions

Office of Terrorism and Financial Intelligence