Frequently Asked Questions

823. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions or activities involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC) that U.S. persons would be authorized to engage in under General License No. 8A (GL 8A)?

… No. Non-U.S. persons generally do not risk exposure under U.S. secondary sanctions relating to Iran for engaging in … agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in otherwise… Read more

853. Can U.S. academic institutions provide online learning services to Iranian students located outside the United States? Can U.S. technology companies provide software and services to assist Iranian students in accessing online coursework?

… General licenses issued under the Iranian Transactions and Sanctions Regulations (ITSR) authorize … to provide certain services and software to Iranian students. These general licenses include: General License G (GL G) authorizes accredited… Read more

844. Do non-U.S. persons risk exposure to U.S. secondary sanctions for engaging in humanitarian-related transactions, or other activities that would be authorized under the Iranian Transactions and Sanctions Regulations and General License (GL) L if engaged in by a U.S. person, involving Iranian financial institutions (Iranian FIs) sanctioned pursuant to E.O. 13902?

… No. Non-U.S. persons generally do not risk exposure to U.S. secondary sanctions for engaging in the sale of … agricultural commodities, food, medicine, or medical devices to Iran, as such transactions are generally subject to exceptions in E.O. 13902 and other… 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?

… NIOC owns a 50 percent or greater interest, that would have been authorized pursuant to a general license in sections 560.530(a) or (b), 560.532, or 560.533 of the ITSR prior to CBI and … E.O. 13224, as amended. Additionally, transactions and activities authorized under specific… Read more

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

… 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 is … pursuant to section 560.537 of the ITSR, those activities should be completed prior to… Read more

243. How can I send personal remittances to or from Iran under the Iranian Transaction and Sanctions Regulations (ITSR)?

… broker or dealer in securities and not by any other U.S. person. The personal remittances general license does not permit a U.S. person to deal directly with money service businesses (MSBs) or hawalas, wherever located. However, this general license does not… Read more

365. What is authorized with respect to brokerage services related to exports or reexports of agricultural commodities, medicine, or medical devices to Iran?

… Iran, provided that the sale and exportation or reexportation itself is authorized by either general or specific license. … Iran, provided that the sale and exportation or reexportation itself is authorized by either general or specific … Read more

367. What is the definition of a “bioactive peptide”?

… For purposes of the relevant exclusion from the agricultural commodities general license in the Iranian Transactions and Sanctions Regulations( ITSR ), the term … For purposes of the relevant exclusion from the agricultural commodities general license in the… Read more

549. In light of the recent earthquake in Iran, how can I help the Iranian people while making sure to abide by U.S. sanctions?

… to the Iranian people, consistent with the Iran-related sanctions administered by OFAC. General License E , issued by OFAC in 2013 pursuant to the Iranian Transactions and Sanctions … of Iran in support of relief services provided by nongovernmental organizations pursuant to… Read more

345. How can U.S. companies arrange for payment from Iran for exports authorized under 31 CFR § 560.540?

… In general, the payment requirements under 31 CFR § 560.540 are the same as for all other general licenses under the Iranian Transactions and Sanctions Regulations ( ITSR ). Section … In general, the payment requirements under 31 CFR § 560.540… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence