Frequently Asked Questions

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. … or other transactions and activities prior to the identification of the financial sector of… Read more

616. Can countries that receive a significant reduction exception under NDAA 2012 purchase oil through NIOC and NICO without facing sanctions?

… for transactions with NIOC and NICO for the purchase of petroleum or petroleum products from Iran while the exception applies. In addition, IFCA provides for sanctions on persons that … for transactions with NIOC and NICO for the purchase of petroleum or petroleum products from… Read more

623. Is there a wind-down or safe harbor provision for Section 8 of E.O. 13846?

… and necessary to the wind down of activities that had been authorized under the now-revoked Iran General License H. To the extent a U.S.-owned or -controlled foreign entity or a U.S. person … and necessary to the wind down of activities that had been authorized under the now-… Read more

314. Can an exporter of agricultural commodities, food, medicine, or medical devices get paid out of a Central Bank of Iran (CBI) account at a foreign financial institution (FFI) in a country with a significant reduction exception, even though the exporter is located in a third-country? Can the third-country exporter’s bank handle this transaction?

… agricultural commodities, food, medicine, or medical devices get paid out of a Central Bank of Iran (CBI) account at a foreign financial institution (FFI) in a country with a significant … agricultural commodities, food, medicine, or medical devices get paid out of a Central Bank… Read more

832. What are significant goods or services used in connection with a sector of the Iranian economy specified in Executive Order (E.O.) 13902?

… knowingly engaged in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with the construction, mining, … facilitated any significant financial transaction for the sale, supply, or transfer to or from… Read more

822. I'm a U.S. person that relied on general or specific licenses pursuant to 560.530, 560.532, or 560.533 of the ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. 13224, as amended. Is any further authorization needed to conduct such transactions following the designations of the CBI and NIOC under E.O. 13224?

… ITSR to conduct humanitarian-related transactions and activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) prior to their designations under E.O. … ITSR to conduct humanitarian-related transactions and activities involving the Central… Read more

845. Will there be a wind-down period for non-U.S. persons engaged in previously non-sanctionable activity involving the Iranian financial sector or Iranian financial institutions (FIs) that are now sanctioned pursuant to E.O. 13902?

… (including any sale) of agricultural commodities, food, medicine, and medical devices to Iran, with Iranian FIs sanctioned pursuant to E.O. 13902. In addition, GL L authorizes under … (including any sale) of agricultural commodities, food, medicine, and medical devices to… Read more

621. What is the prohibition on U.S.-owned or -controlled foreign entities, and how does it work?

… by certain Executive orders prohibiting trade and other dealings with, and investment in, Iran and blocking the GOI and Iranian financial institutions, or any regulation issued pursuant … by certain Executive orders prohibiting trade and other dealings with, and investment in,… Read more

207. What were the criteria for Treasury's CISADA finding against Bank of Kunlun? How many other institutions were you looking at and why did you decide to take action against Bank of Kunlun?

… Kunlun was knowingly engaged in these activities that are sanctionable under the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), the Secretary of the Treasury has … Kunlun was knowingly engaged in these activities that are sanctionable under the… Read more

635. Can I, as a U.S. person or U.S.-owned or -controlled foreign entity, receive payments after the relevant wind-down period ends for goods or services that were fully provided or delivered during the relevant wind-down period under an OFAC wind-down authorization and pursuant to a contract entered into prior to May 8, 2018?

… entity may receive payment through 11:59 p.m. eastern standard time on November 4, 2018 for Iran-related activities undertaken pursuant to section 560.537 of the Iranian Transactions and … entity may receive payment through 11:59 p.m. eastern standard time on November 4, 2018 for… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence