Frequently Asked Questions

302. Are there any exceptions to section 1245 of IFCA?

302 … A person will not be subject to sanctions under section 1245 of IFCA if a determination is made by the Department of the Treasury or the Department of State, as appropriate, that the person has established and enforced official policies, procedures, and controls to ensure that the person does… Read more

303. Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA's section 1246(a)(1)?

303 … A number of insurance activities are subject to sanctions under IFCA , including knowingly providing insurance, reinsurance, or underwriting services to or for Iranian persons on the SDN List to or for any person designated in connection with Iran’s support for international terrorism or WMD… Read more

348. May U.S. persons employ agents in Iran to facilitate sales, create or fund a physical sales presence on the ground in Iran, or utilize Iranian commercial marketing services in furtherance of exports authorized under 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR)?

348 … No. Section 560.540 of the ITSR does not authorize the employment of persons in Iran to facilitate sales, the maintenance of a physical sales presence in Iran, or the utilization of Iranian marketing services. However, the exportation of certain copy-ready advertising materials is exempt… Read more

304. Are there exceptions to insuring, reinsuring, or underwriting sanctioned activities?

304 … Yes. IFCA includes the following exceptions to insuring, reinsuring, or underwriting sanctioned activities. a. Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran or for the provision of humanitarian assistance to the people of Iran can be insured… Read more

417. Are payments or the facilitation of payments not involving U.S. persons to Iranian civil aviation authorities for overflights of Iran or landing in Iran by aircraft that are owned by a non-U.S. person and registered outside the United States sanctionable under U.S. law?

417 … No. Provided that the relevant transactions do not involve the U.S. financial system or persons on the Specially Designated Nationals and Blocked Persons List ( SDN List ), payments of charges for services rendered by the Government of Iran in connection with the overflight of Iran or… Read more

842. What does General License L (GL L) authorize with respect to the financial sector of Iran and Iranian financial institutions (Iranian FIs) now sanctioned pursuant to Executive Order (E.O.) 13902?

842 … GL L authorizes under E.O. 13902 all transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 that are authorized, exempt, or otherwise not prohibited under the Iranian Transactions and Sanctions Regulations (ITSR). E.O. 13902, which was issued on January 10, 2020, is… Read more

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?

843 … No. General License (GL) L extends authorizations provided through specific and general licenses issued under the ITSR to apply to transactions and activities involving Iranian FIs blocked pursuant to E.O. 13902 . Further authorization from OFAC beyond GL L is not required under E.O. 13902… 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?

844 … 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 applicable sanctions authorities… 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?

845 … Yes. Non-U.S. persons engaged in transactions and activities involving the Iranian financial sector or any Iranian FI sanctioned pursuant to E.O. 13902 that were not previously sanctionable will have 45 days to conclude these activities without risking exposure to sanctions. The 45-day wind… Read more

846. How do the sanctions imposed on the Iranian financial sector and Iranian financial institutions (FIs) pursuant to Executive Order (E.O.) 13902 affect waivers issued by the Department of State and exceptions set forth in the Iranian Freedom and Counter-proliferation Act of 2012 (IFCA)?

846 … Waivers issued by the Department of State (State) and exceptions set forth in IFCA remain valid and activities conducted under them involving Iranian FIs are not sanctionable during the wind-down period described in FAQ 845 . Persons engaged in transactions or activities involving the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence