Frequently Asked Questions

241. What are the major changes that the Iranian Transaction and Sanctions Regulations (ITSR) implement in superseding the Iranian Transaction Regulations (ITR)?

241 … The ITSR block the property and interests in property of the Government of Iran and all Iranian financial institutions that come within the possession or control of any U.S. person, including any foreign branch, and prohibit all U.S. persons from dealing with any property interests whatsoever… Read more

242. The ITSR includes revisions to the ITR pertaining to the transfer of funds to or from Iran. Accordingly, how may I transfer funds to or from Iran that arise from, and are ordinarily incident and necessary to give effect to, an underlying transaction that is authorized under the ITSR?

242 … The Iranian Transactions and Sanctions Regulations (ITSR) authorize United States depository institutions to process transfers of funds to or from Iran, or for the direct or indirect benefit of persons in Iran or the Government of Iran , if the transfer arises from, and is ordinarily incident… Read more

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

243 … The ITSR authorize the transfer of funds that are noncommercial and personal in nature to or from Iran or for or on behalf of an individual ordinarily resident in Iran, other than an individual whose property and interests in property are blocked pursuant to § 560.211 , subject to certain… Read more

118. I have a client that is in Iran to visit a relative. Do I need to restrict the account?

118 … No. As long as you are satisfied that the client is not ordinarily resident in Iran, then the account does not need to be restricted. See FAQ 37 . … I have a client that is in Iran to visit a relative. Do I need to restrict the …

54. I have an account with a W-8 showing an address in Iran. Is the account automatically restricted?

54 … In the absence of information proving to your satisfaction that the account holder is not in Iran, you should consider the account restricted based on the W-8 filing. See FAQ 37 . … I have an account with a W-8 showing an address in Iran. Is the account automatically …

533. What are the requirements of CAATSA section 105 related to the imposition of sanctions on the IRGC, and how are those requirements being implemented?

533 … On August 2, 2017, the President signed into law the “Countering America’s Adversaries Through Sanctions Act” (Public Law 115-44) ( CAATSA ), which, among other things, imposes new sanctions on Iran. Section 105 of CAATSA requires the imposition of sanctions applicable pursuant to the global… Read more

534. Before October 13, 2017, wasn’t the IRGC already subject to sanctions? What’s different about applying terrorism-related sanctions to the IRGC and foreign persons that are officials, agents, or affiliates of the IRGC?

534 … Before October 13, 2017, the IRGC was blocked under Executive Order 13382 (relating to WMD proliferation), 13553 (relating to Iranian human rights abuses), and 13606 (relating to Iranian and Syrian human rights abuses via information technology), and persons who engaged in certain activity… Read more

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

260 … A SPECIAL PURPOSE ACCOUNT is an account set up with conditions and safeguards 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 Humanitarian Exception (see FAQ… 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?

549 … In light of the tragic earthquake in Iran, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) would like to highlight some of the ways in which Americans can provide humanitarian assistance to the Iranian people, consistent with the Iran-related sanctions administered by… Read more

261. Are there any circumstances in which funds can be transferred to third-country financial institutions?

261 … Transfers on or after February 6, 2013, of funds deposited in the RECIPIENT ACCOUNT or the SPECIAL PURPOSE ACCOUNT to third-country financial institutions are not covered by the National Defense Authorization Act's ( NDAA ) significant reduction exception , and create exposure to sanctions… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence