Frequently Asked Questions

1088. What are OFAC’s due diligence expectations for cloud-based service or software providers whose services and software support communication tools are authorized by 31 CFR § 560.540?

… exportation of services or software to Iran authorized under 31 CFR § 560.540, OFAC does not generally expect a cloud-based service or software provider to evaluate the ultimate end use or … a prohibited export of software or services to Iran because payroll management software… Read more

1135. How can companies participate in the humanitarian channel in Qatar to export humanitarian goods to Iran?

… involving the Central Bank of Iran and the National Iranian Oil Company are permissible under General License 8A ( see also FAQ 823 ). OFAC FAQ 828 and our Guidance on the Sale of Food, … involving the Central Bank of Iran and the National Iranian Oil Company are permissible… Read more

856. How will transactions related to Iran’s participation in legal proceedings, including administrative, judicial, arbitral proceedings, and proceedings before international courts and tribunals, be treated for purposes of secondary sanctions to the extent that Iranian financial institutions or the Iranian financial sector sanctioned under Executive Order (E.O.) 13902 are involved?

… involving Iranian financial institutions blocked under E.O. 13902 remain authorized under General License (GL) L to the extent they are authorized, exempt, or otherwise not prohibited by … involving Iranian financial institutions blocked under E.O. 13902 remain authorized under… Read more

640. What does the November 5, 2018 amendment to the ITSR do?

… that were previously listed on the E.O. 13599 List. Second, the rule amends an existing general license in the ITSR to allow individual U.S. persons to engage in transactions necessary … that were previously listed on the E.O. 13599 List. Second, the rule amends an existing… Read more

174. What are definitions for the following NDAA terms: “significant financial transaction,” “knowingly,” “owned or controlled by the government of a foreign country,” “food, medicine, and medical devices,” “foreign financial institution,” “Iranian financial institution,” “significantly reduced,” and “whether the price and supply of petroleum and petroleum products produced in countries other than Iran is sufficient”?

… the NDAA on the ITR definition. “food, medicine, and medical devices” “Food”: The October 2011 general license for the ITR and the Sudanese Sanctions Regulations (“SSR”) authorizing certain food … Treasury anticipates closely modeling the definition of this term under the NDAA on… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence