Frequently Asked Questions

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 … to 31… 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?

… (including any sale) of agricultural commodities, food, medicine, or medical devices to Iran; or (ii) to transactions for the conduct of the official business of the United Nations … or otherwise excepted from sanctions: The sale, supply, or transfer of goods and services to… Read more

598. What does E.O. 13846 do?

… 13846, these measures include implementing authority for and additional tools related to: the Iran Sanctions Act of 1996, as amended (ISA) , the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010, as amended (CISADA) , the Iran… Read more

292. What are the implications of IFCA on the provision of humanitarian goods to the people of Iran?

… transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran, as set out in more detail in Q&As 297 and 304 . … What are the implications of IFCA on the provision of humanitarian goods to the people of Iran? …

1110. What are key changes made by the May 17, 2024, amendment to 31 CFR § 560.540 in comparison to Iran General License D-2?

… hardware incident to communications authorized for exportation, reexportation, or provision to Iran previously found in the Annex to GL D-2 is now found in the 31 CFR § 560.540 List of … in addition to the United States, provided that the items were previously exported to… Read more

245. What does the Statement of Licensing Procedure on Support of Human Rights-, Humanitarian-, and Democracy-Related Activities with Respect to Iran do?

… of Licensing Procedure reflects procedures established pursuant to section 413 of the Iran Threat Reduction and Syria Human Rights Act (the TRA). These procedures stipulate that, as … in certain human rights-, humanitarian-, and democracy-related activities with respect to… Read more

315. Will routine payments or fees be subject to sanctions if they are made to a person determined to be a port operator in Iran and if the vessel is carrying non-sanctioned goods?

… 315 … Any company involved in loading or unloading cargo in Iran should exercise great caution to avoid engaging in transactions with entities designated by … States, including the Tidewater Middle East Co. which was designated for its involvement in Iran’s… Read more

645. How will the re-imposition of sanctions on November 5, 2018 impact the provision of specialized financial messaging services to Iranian financial institutions?

… on the provision of specialized financial messaging services set forth in section 220 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA) snap back in full. This authority … to the Central Bank of Iran or Iranian financial institutions… Read more

641. If a country with primary jurisdiction over a foreign financial institution did not receive a significant reduction exception (SRE) under section 1245(d)(4)(D) of the NDAA 2012, can funds currently held at the foreign financial institution in that country on behalf of the Central Bank of Iran be used to facilitate humanitarian trade with Iran?

… Transactions for the sale of agricultural commodities, food, medicine, or medical devices to Iran involving the Central Bank of Iran are excepted from the relevant sanctions under section 1245(d)(2) of the NDAA 2012 and … held at the foreign financial institution… Read more

256. What transactions are impacted by section 504 of the TRA as it amends section 1245 of the National Defense Authorization Act (NDAA) for Fiscal Year 2012?

… conducted or facilitated by a foreign financial institution (FFI) with the Central Bank of Iran (CBI) on or after November 5, 2018 or with a designated Iranian financial institution may be … (ii) the significant financial transaction is for bilateral trade only, and any funds… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence