Frequently Asked Questions

244. What effect will the Iranian Transaction and Sanctions Regulations (ITSR) have on Iranian-Americans and the people of Iran?

… The ITSR include several general licenses that newly authorize, or continue to authorize, activities that are otherwise … The ITSR include several general licenses that newly authorize, or continue to authorize, activities that are otherwise …

811. Can I ship agricultural commodities, food, medicine, and medical devices to Iran via IRISL or E-Sail on or after June 8, 2020?

… U.S. and non-U.S. persons (see, e.g., FAQ 637 ). However, these authorizations and exceptions generally do not apply to transactions with persons designated pursuant to E.O. 13382. Following … or medical devices by U.S. persons or from the United States that are authorized under… 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?

… to give effect to, an underlying transaction that has been authorized by a specific or general license issued pursuant to, or set forth in, the ITSR and does not involve debiting or … to give effect to, an underlying transaction that has been authorized by a specific or … Read more

932. Do U.S. sanctions prohibit U.S. persons from visiting, or making donations to, the Imam Reza Holy Shrine in Mashhad, Iran?

… the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560, and therefore generally are not prohibited. See, e.g., 31 CFR. § 560.210(d) . Exempt transactions include … the Imam Reza Holy Shrine may contact the OFAC Compliance Hotline or may request a specific… Read more

485. What key changes did the December 23, 2016 regulatory amendment to the Iranian Trade and Sanctions Regulations (ITSR) make to the definition of “Iranian-origin goods” or “goods of Iranian origin”?

… device or a personal communications device exported or reexported to Iran pursuant to a general or specific license issued pursuant to the ITSR) and that subsequently have been reexported from and are … device or a personal communications device exported or… 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?

… would require specific authorization from OFAC. OFAC will evaluate such requests for specific licenses on a case-by-case basis. Any request for a specific license should provide sufficient details for OFAC to evaluate the application, including: … for which… Read more

163. What are the differences and similarities between E.O. 13599 and the Iranian Transactions Regulations (ITR)?

… for an Iranian financial institution. The transaction is not exempt or authorized by a general or specific license, and the Iranian bank is not blocked pursuant to the GTSR or the WMDPSR . Previously, … for an Iranian financial institution. The transaction is not… Read more

164. The Iranian Transactions Regulations (ITR) authorize U.S. depository institutions and U.S. registered brokers or dealers in securities to process transfers of funds to or from Iran if the transfer is a non-commercial, personal remittance. Are U.S. depository institutions and U.S. registered brokers or dealers in securities still authorized to process such payments to or from a Government of Iran-owned bank that is not otherwise designated pursuant to another part of 31 C.F.R. Chapter V?

… General License B under E.O. 13599 authorizes U.S. depository institutions and U.S. registered … General License B under E.O. 13599 authorizes U.S. depository institutions and U.S. registered …

855. How will transactions related to official activities of international organizations be treated for purposes of secondary sanctions to the extent that the Iranian financial sector or Iranian financial institutions sanctioned under Executive Order (E.O.) 13902 are involved?

… an Iranian financial institution (Iranian FI) blocked under E.O. 13902 are authorized under General License (GL) L to the extent they are authorized, exempt, or otherwise not prohibited by … E.O. 13902 that would be authorized for U.S. persons under GL L. In addition, Treasury… Read more

847. As a result of the sanctions on the Iranian financial sector and certain Iranian financial institutions (Iranian FIs) pursuant to Executive Order (E.O.) 13902, do non-U.S. persons risk exposure to sanctions for continuing to engage in previously non-sanctionable trade involving the Iranian financial sector or E.O. 13902-sanctioned Iranian FIs, even after the end of the 45-day wind-down period?

… For purposes of E.O. 13902, OFAC would not generally view transactions or activities by non-U.S. persons to be sanctionable if they are … with activities that would be permissible if conducted by U.S. persons. As noted in FAQ 842 , General License (GL) L… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence